In April 2023, the WICHE Cooperative for Educational Technologies (WCET) undertook a national survey to ascertain how and why postsecondary institutions are using Artificial Intelligence to support instruction and learning, what policies are in place, and what are the perceived barriers to, and benefits for, its use. Guiding research questions included:
How and to what extent are postsecondary institutions across the U.S. using AI?
Where is the greatest uptake, use, and impact of AI within and across institutions?
What key issues and challenges are affecting AI use for institutions?
What is the potential for its use?
What types of AI are most likely to impact higher education?
Upon analyzing the over 600 responses, Sebesta and Davis developed several key findings and insights around AI utilization; support, incentives, and training; strategy, planning, and policy; and the challenges and benefits of AI. Some of those key findings include:
Utilization
Using AI to support instruction and learning is nascent on many campuses, although some have been using it for this and other purposes for years.
Concerns about AI and academic integrity – i.e. preventing cheating – are a focus for many institutions and the top reason given for not using AI.
At the majority of institutions, use of AI to support instruction and learning at the institution is on the radar or scattered but there is no systemic action yet. The highest percentage of existing, planned, or considered use is for detecting AI-generated content or plagiarism, with editing and content creation close behind.
Support, Incentives, and Training
Online and Distance Education Administrators and Staff, including Instructional Designers, are the primary roles who are leading this work on their campuses, with faculty and Chief Academic Officers and Provosts (as well as Associate and Assistant CAO/Provosts) close behind. Additionally, on some campuses leaders at the highest level are being engaged in work around AI – and some are including students in AI policy development and practice as well.
The overwhelming majority of institutions do not offer incentives to encourage faculty to use AI, and a majority also reported no faculty development or training around AI.
Strategy, Planning, and Policy
The majority of institutions lack official strategy around the use of AI but have or will be developing policies, primarily around academic integrity and instructional use.
Some institutions are adapting existing policies to include the use of AI.
Challenges and Benefits
Image of “AI on a college campus,” created by Bing AI Image Creator
The primary challenge to using AI was lack of expertise among faculty and administrators, followed closely by lack of policies and guidelines and concerns about protecting academic integrity.
A majority of respondents identified both teaching critical digital skills and learner engagement as the top benefits to using AI to support instruction and learning. Interviews confirmed a need for a new, “digital literacy 2.0” – for both students and faculty – as well as an imperative to include industry in conversations and planning to prepare students for a workforce already using AI. But a new version of the “digital divide” may result from lack of access to training and skills acquisition around AI.
Overall, attitudes about the use of Artificial Intelligence to support instruction and learning range from optimism and excitement about the possibilities, to skepticism and even fear.
A number of respondents expressed that they just don’t know enough about the technologies to be able to predict their impact on the landscape of higher education. One respondent captured what seems to be a common sentiment: “It is the wild wild west. And we don’t have any horses.” And one interviewee argued that AI will upend the very nature of what we do: “The bigger question becomes: What is learning? What is a college education?”
Recommendations
Based on the findings of the survey, as well as interviews with six higher education administrators, staff, and faculty, we have developed a number of recommendations of best practices for the use of AI to support instruction and learning. We understand that each institution and organization has its own unique situations and, therefore, these recommendations may not apply to all. Nevertheless, we hope they will help institutions better plan for, develop, and implement Artificial Intelligence to support student success.
Create clear, consistent, well-developed policies around the use of AI for faculty, students, and others not only to address academic integrity but to anticipate the range of potential instructional uses, intellectual property issues, and others relevant to your context, being sure to include students in policy development.
Provide a secure environment around the use of AI, addressing growing concerns regarding data privacy and AI, through policy, training, and practice.
Leverage AI as a powerful tool to support increased equity for learners, ensuring learner accessibility as well as adequate campus resources, and mitigate impediments to equity in the use of AI.
Develop and teach digital literacy centered on the use of AI to better prepare learners for its utilization in a wide range of workforce sectors.
Review and update course and program curricula regularly to ensure alignment with current, relevant AI skills students will need to succeed in the workforce.
Allocate resources, where possible, to offer ongoing, diverse trainings, both formal and informal, on using AI to support instruction and learning to address the gap in knowledge of AI for faculty, staff, administrators, and students as well.
Engage as many disciplines, departments, and offices internally across the institution and organization – and externally in industry – as possible to develop policy, train, and build a community of practice around AI.
Offer low-risk, collaborative and exploratory opportunities for faculty, students, staff, and administrators to explore and discuss Al.
Conclusion
WCET recognizes that institutions often have limited resources to experiment and collaborate. But as some of our survey respondents pointed out, the use of Artificial Intelligence in higher education – and in other sectors and society in general – likely is not going anywhere and might be well on its way to ubiquity. As one administrator suggested:
[AI] is maybe different in magnitude, but not kind, from the internet. The internet also made plagiarism easier, etc., but it brought great benefits for, say, connecting with students. All advances have drawbacks — I think it’s critical that higher education be thoughtful in our use to try to promote student benefit and avoid abuses.
WCET is committed to assisting its member institutions and all in higher education with navigating those drawbacks while taking full advantage of the advances. You can find existing posts, papers, and webinars on using AI to support instruction and learning on the Artificial Intelligence Resource page on the WCET website. Stay tuned for additional upcoming initiatives and resources on supporting instruction and learning through AI, including an October 25, 2023 pre-conference workshop for WCET members at our Annual Meeting in New Orleans.
This month, WCET will be focusing on enrollment trends and the impact those trends will have on higher education.
To kick off the theme, the WCET Steering Committee work group on enrollment joins us for the start of their Frontiers series on enrollment. We hope you enjoy the series and hope you will join us for our themed events happening this month. Thank you to the work group for this excellent series!
Enjoy the read and enjoy your day,
Lindsey Downs, WCET
Hundreds of colleges have closed since 2004, according to tracking by Best Colleges Most closures occurred in 2018, and the overwhelming majority of them (80%) were for-profit schools. Since the COVID-19 pandemic, Best Colleges has tracked 39 school closures or mergers. Of these schools, 64 percent (25 schools in total) had enrollments of less than 1,000 students; 23 percent (9 schools in total) had enrollments between 1,000 – 2,000; and the remaining 13 percent (5 schools in total) had enrollments over 2,000. The smaller enrollment schools were more likely to list economic concerns or enrollment issues as the primary reason for their closure or merger. Only two of the larger enrollment schools had unclear and sudden closures, while a third lost its accreditation.
While it is true that the overall enrollment of high school graduates in colleges and universities is dropping, enrollments are also shifting away from small, private institutions and for-profit institutions to larger, public, non-profit schools. There is also a gender and racial demographic shift happening with enrollments. In short, there are fewer college-bound students who are less likely to choose small for-profit schools and these students are more likely than in the past to identify as women and Latino.
Enrollments in U.S. colleges and universities have historically fluctuated, but this current drop in enrollments is not like previous ones. In this blog, we will share with you a historical overview of dips and surges in U.S. enrollment in higher education, and we will outline what makes the current enrollment situation different from previous ones.
How it Started
According to the National Center for Educational Statistics (NCES), higher education in the U.S. began with a limited vision of who should receive a college education.
“When the federal Office of Education began collecting education data in 1869-70, only 63,000 students were attending higher education institutions throughout the country, which amounted to only about 1 percent of the 18- to 24-year-old population. This small number of students was divided among 563 campuses, giving an average enrollment size of only 112 students. About 21 percent of students were female” (Snyder et. al., 1993, pg. 64).
This NCES data point does not account for race or gender, although a healthy percent of enrollments were women, this should not be interpreted as widespread acceptance of female students on the part of the nation’s most prestigious institutions.
Multiple Enrollment Surges of New Markets of Students
Postsecondary enrollments grew steadily in the post-Civil War era. The majority of students were white men attending both public and private institutions; many of which explicitly barred female and Black students. However, newly established schools catering to these untapped student markets began to change who was able to get a college education in the United States. There were significant gains in the female collegiate population at schools that accepted applications from women, such as Oberlin College in Ohio, and land grant institutions in the Midwest and West that only allowed women to enroll to secure the financial viability of the school (Thorne, 1985). With the establishment of the Seven Sisters, Mount Holyoke College (1837), Vassar College (1861), Smith College (1875), Wellesley College (1875), Bryn Mawr College (1885), Radcliffe College (1879), and Barnard College (1889), white women finally had schools of their own. Schools to train Black students in trades and as educators were established quickly after the end of the Civil War. “The majority of HBCUs originated from 1865-1900, with the greatest number of HBCUs started in 1867, two years after the Emancipation Proclamation: Alabama State University, Barber-Scotia College, Fayetteville State University, Howard University, Johnson C. Smith University, Morehouse College, Morgan State University, Saint Augustine’s University and Talladega College.”
According to the National Center for Educational Statistics (NCES), higher education in the U.S. began with a limited vision of who should receive a college education.
“When the federal Office of Education began collecting education data in 1869-70, only 63,000 students were attending higher education institutions throughout the country, which amounted to only about 1 percent of the 18- to 24-year-old population. This small number of students was divided among 563 campuses, giving an average enrollment size of only 112 students. About 21 percent of students were female” (Snyder et. al., 1993, pg. 64). This NCES data point does not account for race or gender, although a healthy percent of enrollments were women, this should not be interpreted as widespread acceptance of female students on the part of the nation’s most prestigious institutions.
At the turn of the century, the high rate of immigration to the U.S. contributed to steady gains in college enrollment, although only 2% of the population earned a postsecondary degree. Colleges that began offering programs for professional training—such as business, accounting, engineering, and teaching—enjoyed enrollment bumps due to the popularity of these degree programs.
Small Enrollment Dips and Surges
In the 1920s, enrollments dipped for women and slowed for all populations during the years of the Great Depression. In the 1940s, it was men who left or deferred college for military service. This was the first big dip in enrollments during the modern era. However, thanks to the 1944 G.I. Bill, enrollments of white males surged after World War II. After the passage of the 1965 Immigration Act, new immigrants and international students bolstered enrollment, even as the nation’s birth rate began to drop. Additionally the 1965 Higher Education Act additionally opened new markets of students by providing a subsidy now known as the Pell Grant: a grant created for low-income students to be able to afford a college education.
The big story in the 1970s was the drop in male college enrollment. In 1969, 33 percent of high school men enrolled in college, but, by 1980, only 26 percent of high school men enrolled. What prevented this enrollment dip from being an enrollment cliff was high school women, whose enrollment in college jumped from 21 percent to 25 percent, and it has only continued to increase (aside from periodic dips through 2005). In fact, in the 1980s, women began to outnumber male students enrolled in college, and today women make up nearly 60 percent of all college enrollments.
The Big Dip
The surge of women in postsecondary education programs in the 1980s led to fewer college age students in the current period. Birth rates have been incrementally falling in the U.S. since the late 1960s, with a slight peak in 2006-2007, followed by a faster decline through 2022. Because women with a college education tend to have fewer children than women without a college education, sociologists suggest that the declining birth rate is due to fewer years in their lifetime when women consider pregnancy.
Another new market of students opened up around the 2000s, with college programs designed specifically for adult students who held jobs and had children. An important development coinciding with this new market was online education, driven by the development of new schools like Western Governors University and the University of Phoenix, and the expansion of online branches of existing schools like Southern New Hampshire University and the University of Maryland University College (now University of Maryland Global Campus). Currently, 11 percent of postsecondary institutions in the U.S. offer primarily online degrees, and 14 percent of undergraduate students are enrolled in primarily online programs.
How It’s Going – The Impending Enrollment Drop
For 150 years, U.S. colleges and universities have increased college enrollments by:
expanding who has access to college,
offering new programs that meet student demands, and,
offering new ways of attending college.
But the impending drop in enrollment feels different this time. The U.S. birth rate has been declining for fifteen years, and it is lowest in families who can afford to send their children to college without loans. College costs continue to rise, and subsidies continue to shrink, making college unaffordable for low-income and middle-class families. Outside of adults without a college credential, there are few new markets of students to boost the lost enrollments.
College Costs and Public Funding of Higher Education
Although they’ve been rising steadily since the 1970s, tuition and fees skyrocketed in the generation between Gen X attending college and when Gen Z attended college. From 1992 to 2022, tuition and fees rose 80.24 percent at private nonprofit institutions; 124.64 percent at public 4-year institutions; and 64.96 percent at public 2-year institutions. At the same time, state support for public institutions has plummeted.
“Overall state funding for public two- and four-year colleges in the 2017 school year (that is, the school year ending in 2017) was nearly $9 billion below its 2008 level, after adjusting for inflation. The funding decline has contributed to higher tuition and reduced quality on campuses as colleges have had to balance budgets by reducing faculty, limiting course offerings, and in some cases closing campuses. At a time when the benefit of a college education has never been greater, state policymakers have made going to college less affordable and less accessible to the students most in need” (Mitchel et. al, 2017). Student debt has been cited as a major reason for low home ownership and higher reliance on government relief programs among college graduates, even 20 years after earning their degree. It is leading high school students and their families to question the value of a college credential.
A 2021 survey of high school students by the ECMC Foundation found that fewer than half were interested in a four-year college degree (down from 71 percent), and 65 percent cited the cost of college as an important factor in their decision to attend college, while 43 percent cited the cost of college as the most important factor in their decision. A more recent survey by Gallup and Lumina Foundation found that “Financial barriers are most frequently identified as very important reasons unenrolled adults are not currently enrolled, including costs of programs (55%), inflation (45%) and the need to work (38%).” (Gallup and Lumina, 2023).
Immigration and international students
Another aspect of the enrollment woes being experienced by many institutions relates to international students and immigration. International students often pay full tuition, making them an attractive market for tuition-driven institutions (versus in-state students who may pay significantly less tuition dollars). However, travel restrictions arising from the COVID-19 pandemic led to a significant drop in international student enrollment in U.S. schools in the 2020/2021 and 2021/2022 academic years.
Immigration to the United States also slowed between 2017 – 2021.
“Legal permanent and temporary immigration rose in 2022 after a few years of chill brought about by the COVID-19 public-health crisis and the Trump administration’s restrictive policies and rhetoric. Amid crises around the world, the Biden administration extended or expanded Temporary Protected Status (TPS) for certain eligible immigrants already in the United States and announced special humanitarian parole programs allowing some migrants from several countries to enter the United States and stay temporarily” (Ward & Batolova, 2023).
Why is immigration good for college enrollment?
“Of the 19 million students at U.S. colleges and universities in 2018, 28 percent were either first-generation immigrants or the children of immigrants. Together, these immigrant-origin students play an important role in postsecondary enrollment across the country, accounting for 58 percent of the growth of the student population between 2000 and 2018” (Batalova & Feldblum, 2020).
While institutions may have been able to anticipate enrollment declines among international students and immigrants due to the political climate, they could not have prepared for the greater impact of a global pandemic on their enrollments.
The Perfect Storm
Decreased college enrollment is not simply a matter of falling birthrates shrinking the market of new students: high school graduates who would attend college. The current “enrollment cliff” is the perfect storm of decades of states scaling back funding of public colleges and universities, skyrocketing tuition and fees, a decline in birthrates, a slowing of immigration (which contributed to enrollment rises in the early 1900s and in the 1960s), a global pandemic which added to economic instability, a drop in international students, and young adults questioning the value of a postsecondary degree over the burden of debt.
The changing demographics of college students
Schools preparing to meet the challenges of the decline in high school enrollments, which are expected to peak in 2025, will need to pay attention to changing racial demographics. Among white students, the projected decline is four million; 700,000 among Black students; and 100,000 among Native American/Alaskan Native students. During this same period, there is a projected rise of 3.5 million in high school enrollment for Latino students.
As noted earlier, over the course of the last 150 years, colleges established for young, white men began enrolling students they previously had banned, including women and students of color. Until recently, the expectation of these colleges was that students must adapt to the institution and not the other way around. Title III of the Higher Education Act of 1965 and subsequent amendments have provided recognition and funding for Alaska Native and Native Hawaiian-serving institutions (ANNH), Native American Serving Nontribal Institutions (NASNTI), predominantly black institutions (PBI), and Minority Serving Institutions (MSI). Title V provides recognition and funding for Hispanic Serving Institutions (HSI). In this way, schools have an incentive to provide programs for specific populations of students for whom the institution was not originally designed. However, the demographic shift of students will require colleges to go much further than special programs and scholarships for historically excluded students, who will make up demographic majorities in the coming years.
The Shift in Student Expectations for Colleges and Universities
The scarcity of students enrolling in post-secondary institutions will create a buyer’s market in which students are able to demand more for their tuition dollars. What do students want from college? In poll after poll, affordability, and career readiness are the top considerations that students have when choosing college (see this poll from the National Student Clearinghouse, or the Princeton Review, or Georgetown University). In fact, according to the article about the results from the National Student Clearinghouse, which took a poll of high school students, 60 percent prefer to enroll in career specific programs versus programs balanced with or focused on a liberal arts education.
According to an Every Learner Everywhere report, students want an education that feels relevant to who they are and what they want from life. The report lists the three main takeaways that encapsulate students’ desire for relevance:
Students want to be recognized as individuals and appreciated in the classroom.
Students value the connections instructors make between course content and “real life.”
Students want to be treated with respect and trust.
As a membership organization made up of nearly 900 institutions across the United States, the SAN team considers it of the upmost importance to provide opportunities for our institutional colleagues to share the unique experiences of working in compliance at their respective institutions. It is in this spirit that we invited a select number of individuals to participate in a brief interview that serves to better understand the unique complexities of those working in State Authorization Compliance at Historically Black Colleges and Universities (HBCUs), Minority Serving Institutions (MSIs), Tribal Colleges and Universities (TCUs), and small or faith-based institutions (those with less than 10,000 students). We consider this to be important to the advancement of the knowledge surrounding State Authorization and Interstate Compliance Professionals.
We are pleased to share the themes, thoughts, and insights that were gleaned from those who participated in our interviews. We sincerely thank the participants for taking the time to share their wisdom and experiences with us and find their contributions greatly valuable. We would relish the opportunity to hear from more of our colleagues. Please feel welcome to contact Dr. Jana Walser-Smith (jwalsersmith@wiche.edu) or Kathryn Kerensky, J.D. (kkerensy@wiche.edu) if you are interested. We present to you several major themes that emerged from our interviews and have included quotes and comments from our interview participants below and refer to them by their chosen pseudonym.
Theme 1: Agency, Institutional Support, & Buy-in
Agency is a key concept that plays a significant role in distance education compliance. For the purposes of this work, we refer to agency as the ability of the compliance professional to take control of the decision-making process as it relates to the compliance requirements at their respective institutions. When institutions and institutional leadership foster a sense of agency, it empowers compliance professionals and facilitates their sense of ownership as it relates to programmatic planning, problem-solving, and even plays a crucial role in ensuring student success.
This means being included in important decision-making meetings and having a say in the direction of the institution. Without a seat at the table, employees can feel undervalued and unimportant, leading to low morale and high turnover rates.
As such, several of the participants expressed concern about their lack of agency and/or voice. Others expressed frustration at simply not having a seat at the table. Most agreed that all institutions must understand and embrace the concept of agency.
One of our interviewees, Reese, suggests that “Senior leaders should bring [us] to the table as it would help the institution be more proactive and less reactionary.” April, another participant, finds that “not being a part of the bigger picture makes us feel like we are “not doing [our] job in its entirety”.
April also expresses additional frustration when not being invited to critical meetings. She explains, “…because we are [are not invited] we are missing out on so much information” and “…all compliance staff, would benefit by being brought into these conversations so that they are able to do their jobs effectively”.
Buy-in
In recent years, as leaders in the academy have been exploring new ways to foster growth and innovation within their organizations, one approach that has gained significant popularity is the concept of a buy-in culture. Buy-in culture refers to the degree to which employees are committed to the vision mission and values of the organization. When an employee has a strong sense of buy-in they are more likely to be invested in the success of the organization and to work collaboratively towards common goals
State authorization/distance education compliance has become an increasingly important topic in recent years, as institutions continue to face an array of legal and regulatory requirements. However, achieving and maintaining compliance is not a simple matter of ticking off boxes on a checklist. Rather, it requires a cultural shift within the institution, one that is heavily dependent on the idea of faculty buy-in. Thus, the importance of senior leadership, faculty, and staff buy-in/support in academia is not only vital for student success but also imperative if institutions are to remain viable and ensure sustainability. This buy-in plays a crucial role in the success of both students, faculty, and staff.
Faculty Buy-in
Faculty buy-in refers to the degree to which faculty members are willing to embrace and actively support compliance efforts. Without this support, compliance initiatives are likely to fail or fall short of their full potential. This is critical, as faculty members play a crucial role in shaping the culture of an institution. Their attitudes and behaviors can either facilitate or hinder compliance efforts.
One of the key challenges in achieving faculty buy-in is overcoming resistance to change. Many faculty members may view distance education compliance as an unnecessary burden that distracts from their core academic duties. Faculty may also be skeptical of compliance initiatives that are perceived as bureaucratic or top-down.
When asked about this topic, interviewee Blaine, reports that on his campus, “…faculty buy-in can be challenging”. He added that “… to gain buy-in, you must constantly work with faculty members to provide examples” of the benefits that implementing well-developed compliance programs offer.
Reese echoes a lot of that same sentiment when noting her efforts at her institution, “It feels like [much of my work] is trying to get buy-in and getting people to get on board”. She includes that at the center of her success is “…getting faculty champions to help spread the message because other people in the department take what other faculty say it better than administrators”. “It matters a bit less how much you know and how good you are with people”.
Leadership Buy-in
In recent years, leaders in the academy have been exploring new ways to foster growth and innovation within their organizations. As such, the importance of leadership buy-in in higher education cannot be overstated. If leaders are not supportive of change initiatives, then it is unlikely that their subordinates will be motivated to implement the changes. Contrarily, if leaders are fully committed to change, their enthusiasm and motivation are likely to trickle down and result in a swifter change.
April expressed frustration with the lack of leadership support when recalling a situation wherein she advised her leadership team on a significant change that was on the horizon for distance education compliance. April recalls that her leader discounted and discredited her interpretation of the new regulations by reaching out to a peer institution to better understand how they were approaching this situation. Once it was determined that the peer institution had no immediate plans to react to the new guidance, April was advised that because their sister institution was not addressing the situation, “neither should she.”
When discussing support, another participant, Babs acknowledges that enhanced leadership support could improve the state authorization role at her institution as well. She explains that her charge would benefit from leaders who “build time into their schedules to meet with the compliance person(s) and support the organization of a compliance team”.
According to Reese, “Trying to stay close to leadership and making sure that [her voice is heard] since I am not at the table is exhausting”. She also describes how she makes the extra effort to ensure “that I am on their calendars, in their inboxes, asking questions, and asking for meetings because compliance needs that leadership connection.” Reese notes how her role would be improved if senior-level administrators would bring her to the table, saying “even if there is not a big [title] change, just add me to the invite. [Leaders should] consider me the online campus, consider me a location, treat me as like those other campuses and locations are treated. Be more proactive and less reactionary.”
Contrarily, while some distance education professionals struggle to have voice and agency, we found that several participants who held titles such as Manager, Dean, Director, etc., had more autonomy to make critical decisions and were provided greater visibility to senior-level leaders (versus those who were deemed to be analysts, specialists, coordinators, or compliance managers).
Specifically, in some instances, these individuals were permitted to advise, counsel, make recommendations, and even guide senior-level administrators on specific compliance regulations versus those who were deemed to be analyst, specialist, coordinator, or compliance managers. For example, Jess, a director, explains how she was “allowed to establish, create, and cultivate partnerships and collaborations.” She understands that while “Each campus culture is different, cultures are based on relationships and collaboration. We all must realize that “these are the people you need to get to know to get what you need.”
Jess offered that to be successful, we must “Create a process to have check-ins to look into whatever you need to check-in so you can prepare to complete things such as the annual renewal application”. “I pulled together meetings with Deans, financial, legal, etc.”. “I even established a [compliance] counsel that met twice, but timing became a challenge.”
Jess spoke of the importance of getting a [compliance] counsel active and meeting regularly. She advises that compliance professionals must feel empowered to, “start a process. Keep the website updated.” Leaders must provide the compliance team with “the leeway to set that process and [they must] also take the time to introduce them to the people they need to know.”
In the ever-evolving landscape of higher education, the concept of agency, empowerment, and buy-in continue to be critical factors that impact an institution’s success. While all participants agree that progress has been made, collectively, they contend that empowering compliance professionals, ensuring support and agency, not only equips individuals with the necessary tools and resources to make decisions and take action, but doing so would also lead to increased efficiency, productivity, and job satisfaction.
Theme 2: Lack of Manpower & Funding
There is a myriad of regulatory and legal requirements that colleges and universities must adhere to. As such, remaining compliant is not an easy task. It requires a thoughtful and carefully planned effort for a compliance program to facilitate a comprehensive compliance initiative. However, building this type of costly initiative continues to be a major challenge for Minority Serving Institutions (MSIs), as they regularly face limited funding. This funding disparity is often a direct result of decreases in state appropriations and/or changes in federal student aid programs. However, even as these institutions regularly receive less funding compared to their Predominantly White Institution (PWI) counterparts, they are expected to generate the same results, (mainly improving student outcomes). This, in turn, makes it difficult for the MSIs to fund support and non-academic services.
Jess explains that as an HBCU in a state-run system, “We are expected to operate just like all the other institutions, just like the flagship. Yet we are expected to do so with less resources. Just based on the funding model we’re always going to be underfunded.”
The issue of funding continued to persist across multiple interviews. Coco, another interviewee participant, warns, “we need funding support. We have to train all these people so that they provide the best opportunities for students” and it takes money to do it.
Consequently, compliance-related programs and initiatives tend to take the brunt of the shortage, as it is typical for these programs to have a smaller workforce/lower staffing levels. This results in a lack of time, staff, and other resources that staff feel imperative to be the most effective in their roles. Accordingly, staffing issues throughout the academy have become a growing concern in recent years. An example exists in the fact that 85.7% of the professionals interviewed for this project had compliance teams consisting of only one individual. The majority of our interview participants were not full-time compliance staff but were in the position of directors or managers who were assigned to do state authorization in addition to their other job responsibilities. In fact, the “team of one” premise was a fervent commonality, as Jess told us, “I am still a team of one when it comes to state authorization.”
She continued by explaining that due to the lack of manpower and time constraints, she often spends less than 5 percent of her working time on state authorization compliance issues. “l use my [state authorization] time to double check and ensure that we are compliance; I then try to confirm that there aren’t any issues.”
Angel piggybacks on this concern. Angel is also a team of one when it comes to state authorization and has been able to make it work but believes there is room to grow. A key to such growth is the work Angel is doing to get senior administrators more involved in understanding the implementation, growth, and competition in online education.
Angel suggests, “The ideal thing would be [to have] more people but realistically won’t happen as quickly. In the interim, you learn to be resourceful and request those resources.”
Blaine confesses that if he had more time to dedicate to the role, he would be more effective. He even questions whether this compliance role should live in his department, “I believe that the state authorization compliance role should be [placed] with another compliance officer since it’s not the only compliance task the university has to do…I don’t think that I am doing the role the justice it deserves. For example, the professional licensure program information is not in this office, the responsibility is with the departments. The departments do all of the advising on whether it meets the requirements for the licensure. While I work with them to make sure that their information is up-to-date and then links out to their sites, they complete the huge amount of research that is involved. It’s a huge thing they try to knock out with less time.”
Jess had a similar experience, adding that “I had originally hoped that someone in Legal would take it over [the state authorization compliance responsibilities]”. At one point they started attending webinars and workshops but it [state authorization compliance] still remained my responsibility.”
Many at the institutions we interviewed contend that compliance action tends to be reactive (and not proactive), specifically as it relates to new regulations. Some believe this has a direct correlation to understaffing. It was noted that often an institutional response was the result of a worst-case scenario occurrence and seemed to never be a result of long-term planning.
For example, Angel agrees that state authorization should be a standalone position due to all the intricate details and research it takes to understand the requirements and internally educate fellow institutional colleagues and departments on the requirements.
Jess echoed the sentiment, stating, “we need personnel even if it is part-time” so that someone can focus on the work year-round rather than at key points in the year (ex. SARA (State Authorization Reciprocity Agreements) renewals). Given that Jess has multiple responsibilities on top of state authorization, they find it important to prioritize the most essential obligations and meetings, such as State Portal Entity (SPE) meetings/webinars, and due dates like SARA renewals and data reports.
Babs shares, “I would love to be able to create the dream team of compliance because those conversations would open the ability to have more clout because one challenge is convincing others that we can’t step around compliance. [For our leaders] “It’s easy to say, “This is for students,” or “This is laws and regulations,” or “This comes with a fine or adverse action.” However, it’s hard to convince others, those dreaming up offering their programs across state borders to stick with it!”
To varying degrees and for various reasons, staff turnover presented a challenge to our participants as well. Angel notes that at her institution there have been lots of leadership changes and she finds it because they “have to go back to square one” and explain state authorization and compliance again to new leadership. Although a challenge, Angel has found that leadership likes to be kept in the loop and that the more knowledgeable leadership is, the more they may be able to support the compliance role.
Related to change, April discussed how communication presents a challenge in their role at their institution. As April is not in a leadership role, they have found that they are not kept in the loop when processes or procedures that impact their work change, which has resulted in them having to redo tasks.
Even as the overall growth of state authorization compliance obligations in higher education has been well documented, funding and workforce limitations have seemingly hindered or slowed progress. While it is improbable for any one institution to cover each of their compliance bases, the academy must treat distance education compliance as a living, breathing, animal, or work in progress. Institutions must continue to search for strategic solutions and build long-term plans if they are to remain compliant. However tactically, participants agree that more institutions must work fervently towards building a true culture of compliance.
Theme 3: Passion for Work and Community
Despite any challenges compliance staff may face, a common trait they all shared is passion, whether it be for their institution, job, the students, or all of the above. Blaine said they “really enjoying working here [at their institution] because I know what this institution has meant for this population [of students].” Angel stated that they love “the cultural aspect” of their institution and job, explaining that “there’s a family feeling that’s shared here. When you become a part of the institution, you’re a part of that family, and it’s to your advantage to share that. You want to share that part of you with others.” Similarly, Coco’s favorite part of their job is “the sense of community and the opportunity to make things better.”
The staff’s passion for students was palpable throughout the interviews. Despite having a challenging or sometimes frustrating experience in their role, April stated that “students keep me going. It’s always been that way regardless of the role or capacity I’m in.” Babs felt that it’s honorable that the mission of their institution was recently renewed to be more inclusive and “calls us to be responsible for ourselves and others.” Babs stated that “it feels good to be working within a community with that kind of care woven in.”
Along with that passion is a strong sense of community and collegiality. All participants seemed genuinely interested in sharing knowledge and resources with those at their institution and with their colleagues at other institutions.
We asked what advice they would give to someone starting out in state authorization or struggling to get launch their programs:
Partnerships and collaboration first. Create those relationships with those who are really going to be integral pieces of your work in state authorization. Make a great rapport with them so that you can get their buy-in.
Engage politically, be collaborative, and be a good communicator. It’s important to be good at change management and being with people.
Absolutely be engaged and attend all the meetings you can. It is important to be on top of communication to maintain compliance.
It’s okay to take your time and focus on one important thing every now and then. Start from where you are, take your time to learn.
Be very resourceful, resilient, and patient. It takes a village with patience and time. It can feel overwhelming at times but if you take tasks one day at a time, it is easier.
It is very imperative to be an active listener. Being an active listener provides an opportunity for mutual understanding and allows for engaging communication.
Communicate clearly what the expectation is and ensure others clearly understand the information and resources available to them.
Do the research, stay organized, and pay attention to detail. It is important to stay knowledgeable.
Solutions
Despite the challenges faced, our participants illustrated the various ways that have approached such challenges and the solutions that they have found the most effective in their work.
Solution #1: Resourcefulness
Regardless of the individual’s institution, title, or perspective, a common theme among our interviewees was the importance of resourcefulness, of both the compliance staff member and the institution in general. According to April, she would advise compliance staff members to “be a go-getter” and to be persistent less some doors close. Similarly, Angel stated that compliance staff need to be “very resourceful, resilient, and patient” and “learn to use your resources including those at your institution and those at other institutions.” Jess echoed these sentiments, stating that compliance staff must be “able to be very resilient” because they are “expected to operate like all the other institutions” but “with less resources.” This has resulted in Jess and her institution “learn[ing] to do more with less.” The lack of resources and need for resourcefulness has in many instances built a sense of camaraderie and support in other ways. Jess mentioned that she felt her institution would support the hiring of additional staff if not for the lack of funding and having this recognition has helped keep her grounded.
Solution #2: Relationships
Across the interviews, regardless of institution or the individual’s role, our participants highlighted the importance of building and sustaining relationships as key to success as a state authorization compliance professional. Reese believes that the most important things are to “engage politically, be collaborative, and be a good communicator” and that “it matters a bit less how much you know and more how good you are with people.” April agreed that it is extremely important to build rapport with everybody who can be directly impacted with state authorization. To April, creating “those relationships with those who are going to be integral pieces of your state authorization work” is “extremely important.”
Jess would advise new staff to prioritize “partnerships and collaboration first.” To Jess, even if campus cultures differ, those cultures are “based off relationships and collaboration” and it is important to understand such and get to know people that you need to work with. Jess advised that compliance staff should “create a process to have check-ins” with those key individuals to do the work that needs to be done. Coco believes it is “very imperative to be an active listener” and that “being an active listener provides an opportunity for mutual understanding and allows for engaging communication.”
Thank You
It goes without stating that this work requires dedication, collaboration, commitment, and institutional support. Often, distance education compliance professionals are also engaged in multiple (additional) duties/responsibilities, while simultaneously remaining vigilant about this work. Most importantly, these individuals carry out and successfully complete this work despite difficulties and obstacles.
It was evident with each of the interviews that all participants were not only consummate professionals, but also champions of this work. All were gracious with their time, honest with their responses to the questions asked, and refreshingly open when recalling their lived experiences.
We cannot convey enough how grateful we are to our interview participants for sharing their knowledge with us. We hope that readers have learned more about the perspectives of their institutional colleagues and have found similarities in their own experiences.
Dr. Karen Cangialosi, Director, Every Learner Everywhere
I want to respond to this question by amplifying the voices of black leaders, and the Juneteenth dedication of thought leader, writer, activist, and change agent, adrienne maree brown, who quotes several black genius revolutionaries. The wisdom of these black women sustains and inspires me every day to do the work that I do:
“our radical imagination is a tool for decolonization, for reclaiming our right to shape our lived reality.” (adrienne maree brown)
“all that i touch, i change. all that i change, changes me. the only lasting truth is change.” (octavia butler)
“i have to act as if it were possible to radically transform the world. and i have to do it all the time.” (angela davis)
“until the killing of black men, black mothers sons, becomes as important to the rest of the country as the killing of a white mother’s son, we who believe in freedom cannot rest.” (ella baker)
“when i dare to be powerful, to use my strength in the service of my vision, then it becomes less and less important whether i am afraid.” (audre lorde)
“if i hear the dogs, keep going. if i see the torches in the woods, keep going. if there’s shouting after me, keep going. don’t ever stop. keep going. if i want a taste of freedom, keep going.” (harriet tubman)
“black lives matter. black trans lives matter. black disabled lives matter. black queer lives matter. black children’s lives matter. all black life matters.” (alicia garza)
Shannon Riggs, WCET Steering Committee Past Chair, WCET Executive Council, Executive Director of Academic Programs and Learning Innovation, Oregon State University Ecampus
Oregon State University’s President’s Commission on the Status of Black Faculty and Staff Affairs recently held its second annual summit, the State of Black Affairs Summit 2023. The summit was a full-day conference that offered concurrent sessions on important topics such as the multidimensionality of Blackness, Black public health, supporting Black rural students, creating inclusive spaces, and effective allyship and mentoring. The day also included a keynote by Oregon State Representative Travis Nelson regarding how attendees can get involved in local government to advance DEI priorities. It was an educational and inspiring event.
Patti O’Sullivan, Content Manager, Every Learner Everywhere
People talk today about Black contributions to the development of the nation being erased, but in my experience, they were never there to begin with. As a child in public schools, the only information I was taught about Black Americans was their enslavement and their achievement of Civil rights. Starting in college I had to deliberately choose to take classes that featured the stories and achievements of Black American in order to learn about them. I’ve continued that learning thirty years after graduating with various resources in multiple modalities. In my experience, white Americans must choose to learn the fullness of our nation’s history, even when – especially when, it reveals how our whiteness has been used to justify great harm to others. Some might describe this learning journey as divisive, but I disagree. It is humbling, enlightening, and healing. What is truly divisive is to willfully ignore the lived experiences of Black Americans and to expect them to move on from a trauma for which white America has never fully acknowledged or atoned. Below I’ve listed some of my favorite, recent resources for learning about Black history.
Lindsey Downs, Assistant Director, Communications and Community, WCET
Diversity, to me, is what makes each of us unique and those elements that make each of us who we are (such as our backgrounds, experiences, beliefs, etc), are valuable elements to a vibrant, interesting, and successful community. When we limit a side of ourselves, we personally become less able to contribute to our family, community, and the world in a meaningful way. The same can be said about limiting the inclusion of others. An exclusive world, to me, is a less meaningful one. This is why our work in DEI is important to me. Juneteenth is, in the words of the Smithsonian Institute, “our country’s second independence day.” I really never knew about this important day until I was in college. I took a Critical Race Theory course at Montana State University, and I will forever be grateful for that opportunity. Unlike some understandings of this type of course, my experience was a thoughtful and thorough review of how laws, policies, and societal structures have been and continue to be shaped by people’s concepts of race. The course was eye-opening for me. I am so thankful that I was able to take this course with a wonderful group of other graduate students and a great professor, and I continue to be thankful that my team at WCET supports us in not only extend our DEI knowledge and experiences but pushes us to examine how our personal work, projects, the content we create, etc., is or isn’t inclusive and to make adjustments to ensure our work reflects our equity principles.
In reflecting on this post, I determined it was important for me to develop a personal diversity and inclusion statement, in addition to assisting with the equity work WCET is actively doing. I have a lot to learn about our country’s history and how privilege and racism still impact so much of our world.
You can get a hint of my personal statement in my words today. There are many ways to go about writing such statements and I encourage you to consider using the Juneteenth holiday to brainstorm your own personal statement on these issues. While mine is definitely still a work in progress, I know having the statement will allow me to complete my work and go about my personal life in a more inclusive and open mindset. And, as we all know, that’s the best possible state to be in when we’re learning. Here are some resources for crafting a personal DEI statement:
Su Jin Jez, Every Learner Equity Advisory Board Member, Executive Director, California Competes
I am fortunate to be based in California, a racially diverse state that largely embraces and celebrates this diversity. Growing up as a mixed-race individual, I have memories of my parents being very intentional in their conversations about both Black and Korean culture, values, and histories with me and my brother. These conversations have deeply influenced me and continue to shape how I raise my own children, as well as how I interact with my colleagues and peers. It is essential to me that I bring this same mindset of intentionality and cultural appreciation into my work to reshape California’s higher education system into one that is equitable and inclusive.
At California Competes, we view understanding the historical and systemic underpinnings that have led to today’s racial inequities as a central and ongoing aspect of our work. For Juneteenth, our team will reflect on the holiday and what it commemorates. Over a shared meal, we’re inviting staff to share their favorite resources on black history, creating an environment where everyone can learn from each other and deepen their understanding of the historical significance of Juneteenth and the ongoing fight for racial justice.
Danielle White, Every Learner Student Intern, George Washington University
As a Black student at a private PWI, I engage in student run organizations that were established to maintain a safe space for the Black community. I believe that this promotes Black history by asserting our seat at the table, where we could not formerly sit. As the director of my institution’s gospel choir, I remind my members of the pain that was used to cultivate Black art. As the event planner for Young Black Professionals in International affairs, I remind my peers of the giants that came before us, who did not receive credit for their contribution to American Foreign Policy. We reflect on Black history in order to motivate the mission, and the change that we wish to create on our campus.
Russ Poulin, Executive Director, WCET & Vice President for Technology-Enhanced Education, WICHE
You Belong Here
Thinking about this Juneteenth made me think about the history of the holiday and the persistent inequities facing higher education. One of those inequity concerns surrounds falling college and university enrollments and the fear that it will get worse with the pending “enrollment cliff.”
Could these downturns reverse the years of trying to improve enrollments for Black, Latino, Indigenous, and other students of color? Some data analyses have shown that is the case.
In recent weeks, I have been hearing about institutions that have been innovative in finding ways to welcome potential students who might not otherwise even consider enrolling:
The President of Northern Arizona University learned that many of the Latino residents of Flagstaff had never set foot on campus. It was not a place for them, although they often had to drive around it to get from one side of town to the other. He created an on-campus experience that invited school children to an extended visit. It gave the largely Latino youth a new vision of their possible future right in their own back yard.
Boston University acquired a local institution that was closing. From it, they developed the Pine Manor Institute for Student Success “aimed at enhancing educational opportunities for underrepresented and first-generation students.” The Academy is one component that grade 8-12 students to a summer enrichment program. These enrichment programs let Black students experience that college is a place for them. They are also starting a mentoring program and a new, residential two-year college to being in 2024.
It is all about overcoming history. The message of that history is that those population is that they can come to college but they are not welcomed or, worse, that they are to stay away from postsecondary institutions.
For those of us using digital learning, our history includes concerns about equity issues and retention rates for populations that are traditionally not well-served by higher education. What are we doing in online and digital learning to welcome them? What extra outreach is needed? What extra support is needed? What type of personal touch is required?
Juneteenth is a holiday based on messaging. The enslaved people were late in learning that they were free. How do we deliver a new message today…. that higher education and online education are places not only where they are welcomed…but where they belong?
The Equal Justice Initiative states, “as an opportunity for national reflection, Juneteenth invites us all to confront the promises of liberty and justice that remain largely unfulfilled in this nation. Through this reflection, we can recognize and commit to addressing the legacies of racial injustice present in our lives today. Strengthening our understanding of racial history empowers us to create a healthier discourse about race in America and foster an era of truth and justice.” Every Learner and WCET are dedicated to reflecting, recognizing and committing to addressing racial justice in our work with partners, peers, institutions and students. Juneteenth reminds us that US Black History is under attack today, just as it has been for more than 150 years. Today we celebrate the freedom of African Americans, honor their achievements, and work to catalyze change in dismantling systemic racism and removing structural barriers to educational equity for every learner, everywhere.
Thank you to those who contributed to this post and sharing how you encourage students, colleagues, and peers to reflect on Juneteenth and Black History to sustain the work for equity in education.
To learn more about Juneteenth, and racial injustice throughout US History, we recommend visiting the Equal Justice Initiative, A History of Racial Injustice Calendar, for more information and resources.
The WCET Steering Committee Microcredentialing workgroup is a small and passionate group of higher education leaders and practitioners. Led by Krysia Lazarewicz, Wiley University Services, and Suzanne Ehrlich, University of North Florida, the group has had discussions since December 2022 about where WCET can provide value and avoid duplication of work being led by other organizations.
Throughout the initial meetings, it became apparent that WCET should do what WCET loves to do anyway – collaborate as a community to share knowledge and experiences. The conversations between committee members were cathartic and reenergizing. They helped each other sort through the noise and surface potholes along the microcredentialing highway. This Frontiers blog is a result of those shared stories about opportunities and challenges.
Although everyone has a different map and destination, hopefully this blog post helps you navigate some of the potential potholes on your microcredentialing journey.
The Potholes
Definitions and Taxonomies
Microcredentials represent focused units of learning that validate specific skills and competencies. Microcredentials are typically a digital record of achievement of a skill or competency. There are various definitions across leading higher education organizations and currently, there is not a single industry recognized definition of microcredentials. WCET published a blog post in June 2022 about the definitions and the need for clarity at the start of a microcredential initiative.
Digital Promise defines a microcredential as “A competency or skills-based recognition that allows a learner to demonstrate mastery and learning in a particular area (Digital Promise).”
WCET recommends the following resources for definitions and key terms:
Establishing your institution’s working definition at the inception of a microcredential initiative provides clarity throughout the development and implementation of a program. The WCET working group found that spending time on crafting the ideal definition delays progress; therefore, find one that aligns with the mission of your institution and goals of the microcredential initiative, and get to work.
Verifying and aligning the skills and competencies acquired through microcredentials is crucial. Start small. Begin with a single noncredit microcredential and eventually scale up from there. Determine how competencies will be assessed. Assuring that competencies are assessed and meet or exceed quality standards are essential to the integrity of the microcredential certification. Partnerships between institutions, industry patterns, and professional organizations build trust and validity in microcredential.
Goals and Audience
In WCET’s May 2022 blog post, the authors wrote “When considering whether a microcredential strategy is right for your university, it’s important to begin with the end in mind. When your strategy is a wild success, what will be different for your learners and for your university? What will you measure, observe, or be able to report that highlights the ways that microcredentials have added to your overall impact as an institution? And perhaps most importantly, what will students say when asked how they have been impacted?”
Define your institution’s initiative goals. Microcredentialing is a lower barrier of entry for learners who may not be able to commit to a full degree but are still looking to invest in their potential. For students currently enrolled, a microcredential can aid completion by recognizing units of learning, rather than the zero-sum game of no credential unless a degree is attained. Typically, institution’s goals include one or more of the following:
Student recruitment,
Student retention,
Supporting lifelong learning,
Credit for prior/co-curricular learning,
Enabling students to upskill and improve employability and earnings,
Providing employee benefits,
Professional development for faculty and staff.
Goals that align with the institution’s strategy and mission, as well as meet the needs of learners/earners, are most effective. By aligning microcredentialing with the goals of the institution and identifying the right target market, funding is more likely as microcredentialing is viewed as an opportunity, not a barrier.
Funding and Investing in Microcredential Initiatives
The F word doesn’t have to be a pothole. Funding models for microcredentialing include:
grants,
institutional support,
funding through fees, and,
in limited circumstances, financial aid.
Educational benefits such as tuition reimbursement, subsidies, or employer-sponsored programs may also be available. These benefits incentivize learners to acquire new skills and competencies while reducing financial barriers.
Financial hurdles are another reason to start small and eventually scale up microcredentialing programs. Determine how costs will be covered, how ROI will be calculated, how the program will be marketed, and a timeline for sustainability. Clearly stating the reasoning for microcredentialing at your institution is key to calculating the return on investment and allaying fears of cannibalization of course or program enrollment.
Strategy and Leadership
Courageous leadership is key to a successful microcredential initiative. Strong leadership convenes key stakeholders, develops policies and procedures, outlines the strategy, identifies the goals, establishes metrics, and continually seeks process improvements. Leaders work across the institution to continually communicate, and pivot as needed.
Successful implementation of microcredentials requires collaboration among various stakeholders including industry experts, employers, faculty, admissions, the registrar’s office, and students in conversations surrounding the design and development of microcredentials. Creating a strategic roadmap that aligns microcredentials with the institution’s mission, vision, and long-term goals is essential for sustainable implementation and success.
Conclusion
Microcredentialing is gaining momentum as students spur demand, employers recognize the value of shorter-term certifications, and institutions see the opportunities for recruitment and retention. As your institution explores or evaluates microcredentialing, consider the road ahead, view the opportunities, plan for a few bumps, but know you can avoid the potholes.
WCET members, this month’s Closer Look Guide, sent through wcetNEWS, dives further into these topics. Additionally, the Closer Look covers:
Considerations for Diversity, Equity, and Inclusion.
Hello and welcome to WCET’s annual summer media review and recommendations list!
Each summer we like to share our staff’s recommendations for fun reads, listens, and watches for the summer. These suggestions are a mix of personal and professional development podcasts, books, articles, and shows.
We hope you enjoy our recommendations and that you are enjoying a great start to the summer!
I picked this one up last year to learn more about Juneteenth. The short book does cover that history briefly, but goes deeper into racism and struggles to overcome it in her life in Texas. It also gives a deep history of how racism was built into that state’s structures from the first settlers who came to Texas from what became the Confederacy to a state constitution that favored some over others. Since this is being published close to the holiday, it is still a good reminder of what is history and of what persists.
– Russ Poulin, Executive Director, WCET & Vice President for Technology-Enhanced Education, WICHE
Earlier this year some members of the WCET team held a book club in which we shared our views on John Medina’s Brain Rules for Work: The Science of Thinking Smarter in the Office and at Home. The author has been a frequent keynote speaker after the success of his original book, Brain Rules.
Medina is a molecular biologist focused on the research on human neural development. Throughout the book he cites research in tackling in the chapters: Teams, The Home Office, The Business Office, Creativity, Leadership, Power, Presentations, Conflict/Bias, Work-Life Balance, and Change. The accompanying website includes two bonus chapters on Grief and Personality. And his 10 brain rules for work include “Teams are more productive but only if you had the right people.”
While scientifically based, the book is readable for everyone. The insights and recommendations lead to useful discussions among your team members. Since it is a book for the masses, it does not go deep into the studies he cites. A reference list would help. Enjoy engaging fellow staff members with this book.
Academia is often called out for its many issues around race. This book addresses that topic, describes several personal stories, and challenges the way that academia tends to exclude and restrict access for many women of color. While framing the chapters as if they are sections of a course syllabus, the author thoroughly describes the need for developing community in academia and the role that these communities play in supporting people of color in an overwhelmingly white space. She furthermore points towards specific things that could be changed to create better equity and inclusion in academia.
I’m cisgender (the opposite of transgender, meaning that my gender identity is the same as the gender that I was assigned at birth), and as such, I sometimes feel like I don’t understand much about what it means to be transgender. I’d like to be a good ally and found that this book was really useful in helping me do better. This book helped me understand more about transgender experiences and the obstacles that transgender people often face. Author Shon Faye is a transgender woman in the UK who writes about trans “issues.” Faye explains that transgender people themselves are often seen as an “issue,” but she turns that phrase around by explaining the issues that are faced by – not unfairly blamed on – trans people. I highly recommend this book for everyone, but especially for people like me who feel like mainstream media has not done an adequate job of explaining trans rights.
I just completed an MS in cybersecurity and during the program I learned about how the internet works. I think it’s pretty cool that I actually understand how this essential and omnipresent artifact works, and then I think back about how strange it was that I never questioned much about its functionality before I learned about it. While most books out there that describe the internet seem quite dense and difficult to unpack, there is an occasional gem, and this book happens to be one of them. It is a great book for explaining the basics of network engineering and internet governance. Although it covers some very complicated subjects, I think the authors do a good job of putting the information into language and visuals that are easy to consume. Furthermore, with an illustrated cat by the name of Catnip as the central character alongside a cast of other creatures and personified objects, the visual experience creates an adorable setting to learn about any subject.
– Rosa Calabrese, Manager, Digital Design, WCET
I have not actually read any of these books, but they’ve been on my list for a while and I’m hoping to get to them this summer:
Parent Nation,
From the Hood to the Holler,
The 1619 Project.
– Kathryn Kerensky, Director, Digital Learning Policy & Compliance,WCET SAN
Before Owen Michaels disappears, he smuggles a note to his beloved wife of one year: Protect her. Despite her confusion and fear, Hannah Hall knows exactly to whom the note refers—Owen’s sixteen-year-old daughter, Bailey. Bailey, who lost her mother tragically as a child. Bailey, who wants absolutely nothing to do with her new stepmother. As Hannah’s increasingly desperate calls to Owen go unanswered, as the FBI arrests Owen’s boss, as a US marshal and federal agents arrive at her Sausalito home unannounced, Hannah quickly realizes her husband isn’t who he said he was. And that Bailey just may hold the key to figuring out Owen’s true identity—and why he really disappeared. Hannah and Bailey set out to discover the truth. But as they start putting together the pieces of Owen’s past, they soon realize they’re also building a new future—one neither of them could have anticipated. With its breakneck pacing, dizzying plot twists, and evocative family drama, The Last Thing He Told Me is a “page-turning, exhilarating, and unforgettable” (PopSugar) suspense novel. Also a TV series on Apple TV starring Jennifer Garner.
– Patricia O’Sullivan, WCET and Every Learner Everywhere
We haven’t read this yet, but this book was just selected as the book club read for the ASWE book club for 2023. ASWE attendees will read the book prior to the WCET and ASWE meetings this fall and meet during ASWE to discuss.
The book overview: Michelle Obama offers readers a series of fresh stories and insightful reflections on change, challenge, and power, including her belief that when we light up for others, we can illuminate the richness and potential of the world around us, discovering deeper truths and new pathways for progress. Drawing from her experiences as a mother, daughter, spouse, friend, and First Lady, she shares the habits and principles she has developed to successfully adapt to change and overcome various obstacles—the earned wisdom that helps her continue to “become.” She details her most valuable practices, like “starting kind,” “going high,” and assembling a “kitchen table” of trusted friends and mentors. With trademark humor, candor, and compassion, she also explores issues connected to race, gender, and visibility, encouraging readers to work through fear, find strength in community, and live with boldness.
Malcolm Gladwell is noted for writing books (The Tipping Point, Blink, Outliers) at which he looks at societal and business hidden realities, trends, and changes. He produces only a handful of episodes per year and they are both enlightening and entertaining. I particularly point you to some episodes from Season 6 (2021):
I highly recommend two episodes that are critical of US News & World Report college rankings: Lord of the Rankings and Project Dillard. If you didn’t know how hollow those rankings are, Gladwell lays it out. You will especially enjoy the conversation he has with the individual who is the “lord of the rankings.” I have talked to him and that is how it goes. Project Dillard shows how an HBCU can improve its rankings. The answer? Grow. Become exclusive. And don’t worry so much about serving Black students. Makes me mad and is funny.
He also has three (yes three!) episodes on The Little Mermaid, which is again timely. The episode is focused on an article about law and morality in Disney animated films. He asks in the first episode…do we need to overthink animated movies of fairy tale? He concludes “Actually, we do.” An illegal contract does not win out over a just outcome. Makes you think and is funny.
Anyone else here who doesn’t like horror movies, but wishes they liked horror movies? I’m too easily terrified by horror to watch it myself, but I always want to know what happens in popular horror movies, so I often find myself reading spoiler articles about them. And I always thought I was the only person who was like this because it does seem pretty weird. But then I found the Ruined podcast! The premise is that one woman tells her friend (who is a scaredy cat like me) exactly what happens in a different horror film each week. Then they discuss things like mistakes the characters made and what they would each do in the same situation. The episodes are typically quite funny, and don’t bring about the same dread inside of me that watching horror movies does.
In this series, Doireann aims to delve into the beauty of having a laugh, speaking to guests from all walks of life. From first memories of laughter to being laughed at to “if I didn’t laugh I’d cry” moments, these markers shape the interviews, bringing out the best in some of Ireland’s most influential people.
– Patricia O’Sullivan, Content Manager, WCET and Every Learner Everywhere
Holly Frey and Maria Triarchi look at historical crimes and examine them with a more modern viewpoint and the benefit of hindsight. Seasons have included “Treasonists,” “Artnappers,” “Resurrectionists” (or body snatchers), “Witches and alchemists,” “Lady Pirates,” and more! The hosts do a great job of researching and presenting stories from the past that I thought I knew a lot about (in some cases anyway) but common understandings weren’t the whole story. Plus, at the end Holly and Maria present mocktails and cocktails inspired by each story and/or crime, which is a fun little bit for each episode.
– Lindsey Downs, WCET
Some podcasts I like that are related to education are Times Higher Education, Teaching in Higher Ed, and Higher Education Matters. I also like Science Vs, Planet Money, Latino USA, and Stuff You Should Know, but they aren’t super related to higher education.
I’d be remiss if I didn’t mention OUR PODCAST. Did you know WCET has a podcast? Check out the WCET Frontiers Pod for our monthly (at least) episodes on solutions and innovations in the practice and policy of digital learning in higher education. Get caught up and subscribe now to get notified when future episodes are released! We’re on Apple Podcasts, Google Podcasts, and Spotify.
– Lindsey Downs, WCET
TV
I’m looking forward to these TV shows this summer:
Crime Scene Kitchen – this is like a combination of cooking show and detective series. Essentially, teams of two work together to try and investigate ingredients, crumbs, utensils left behind in a kitchen to see if they can replicate the dessert that had been made. I will say I’m not one who usually enjoys the typical cooking shows, but this is one that both me and my husband enjoy.
Claim to Fame – this was a surprise favorite of ours last year. Essentially, a group of relatives of various celebrities are put together in the house and they have to try to keep the identity of their celebrity relative a secret in order to last to the end of the game and win. Clues are revealed to the contestants throughout the game that hint toward who each person’s celebrity relative is.
Stars on Mars – I’m not fully sure of the premise of this show but I think celebrities are essentially competing against each other to see if they could last in a simulated Mars environment.
– Kathryn Kerensky, Director, Digital Learning Policy & Compliance,WCET SAN
If there is anyone out there wondering if they should watch Ted Lasso, well, here is your sign to watch it.
I can honestly say that this show was not only one of my very favorite television shows I’ve ever seen, but some of the episodes (especially this season) have, in my opinion, been some of the best episodes of TV ever. I know many would disagree with me, especially on this season, but to me the acting, writing, and production was top notch. They tackled some big topics and did surprisingly well in doing so. Plus even when things got heavy, they found a way to add some humor when it was really needed. Which I think we all need to know how to do sometimes. And you don’t need to know anything about football (/soccer) to enjoy the show. I laughed and cried so many times this season and I’m still a tad in denial that it’s over. It was absolutely lovely.
As higher education institutions seek to support learners in a more holistic and comprehensive manner, many are turning to wraparound services to ensure that learners’ full range of needs are addressed.
Specifically, wraparound services are programs and support initiatives that go beyond assisting learners with the normal rigors of academics.
These programs often help with non-academic needs such as:
mental and behavioral health,
housing and food insecurities,
social support, and,
familial issues like those involving transportation or childcare.
Why Wraparound Services?
Even as wraparound services are rooted in the medical practice of Systems of Care, or the community-based processes wherein healthcare providers coordinate their care to support the patient holistically, these praxes are becoming increasingly important in higher education.
One rationale for increasing wraparound services stems from the challenge postsecondary institutions face to expand equity and increase accountability. This has caused the academy to re-imagine ways to facilitate learner success.
As a result, it has become increasingly clear that a more holistic approach to learner support is needed to ensure both academic and personal success. Contemporary research also encourages this holistic approach, informing that learners who receive wraparound services are more likely to not only persist but also graduate. As such, colleges and universities nationwide have opted to implement a myriad of these programs.
Service Examples
Wrapping Up Food Insecurities
An example of new and innovative support services stems from the rising concerns related to food insecurity on college campuses. To respond, a number of institutions have implemented new student food assistance programs. One such program is the University of North Carolina Greensboro’s, Spartan Open Pantry, a campus-based food support system that allows students’ access to a variety of perishable and non-perishable foods, fresh fruits and vegetables, and hot meals.
Greater than 500 colleges and universities throughout America have also implemented the Swipe Out Hunger initiative on their campuses. Institutions such as the University of California, Los Angeles, University of Colorado, Boulder, and Texas A&M University, College Station, launched this program which simply allows students to donate unused meal swipes to their peers in need. Another program is the Food for Thought initiative, which was established during the COVID-19 pandemic as a means to provide learners with access to free or discounted meals. This programming has been implemented at prestigious and nationally known institutions including the University of Michigan, Ann Arbor and the University of North Carolina, Chapel Hill.
Empowering Learners with Mental Health Assistance
In the wake of the COVID-19 pandemic, college campuses nationwide have seen an uptick in concerns about the mental health and well-being of learners. The perfect storm of the pressures of academic performance, social expectations, and the transition to adulthood, coupled with pandemic-related closed campuses, adjusting to online learning, and, for some, the death or illness of family, increased reports of learners experiencing stress, anxiety, and depression. According to the American College Health Association, nearly 40% of college students reported feeling so depressed in the past year that it was difficult to function.
To address this issue, campus administrators are taking steps to improve mental health support for their learners by increasing the number of counselors and mental health professionals available on campus, as well as expanding the hours and availability for counseling services. Some universities are also implementing peer support programs, where trained student volunteers provide confidential support and guidance to their peers.
In addition, the academy continues to work to develop a more supportive and inclusive campus environment. This includes offering mental health awareness and education programs, promoting self-care, stress management techniques, and reducing stigma around seeking help for mental health concerns. Some universities have also implemented policies and practices to address the specific needs of marginalized and underrepresented student groups, such as LGBTQ+ students and students of color.
While Georgia Institute of Technology, Atlanta, bursts with pride when lauding the rigors of its academics and research programs, as well as the strength of its students, the university is also going to great lengths to publicize its Wellness Empowerment Center. The center incorporates programming on financial well-being, sexual health, self-care, etc., by using an “upstream approach” which works proactively to prevent student mental health issues. Administrators contend that by implementing innovative programs and wellness initiatives, they, in turn, facilitate learners’ ability to “always thrive as they move upstream.”
Community Partners
While some institutions have established campus-based centers that offer a range of these services, others have engaged in developing partnerships with community organizations to provide a mix of services. Third-party service organizations such as GraduLet in Houston, Texas, AdvanceEDU in Denver, Colorado, and College Together in Philadelphia, Pennsylvania, have partnered with several institutions across the country to provide enhanced learning opportunities for students.
Partner agencies also assist students with completing complicated federal financial aid applications, provide academic and personalized student success coaches, tutoring and writing center assistance, skill-building workshops, and special help for English language learners. Non-traditional assistance includes transportation support such as public transportation passes, onsite childcare, hot meals, healthcare referrals, mentorship programs, and dedicated workspaces.
The intent is for learners to become immersed in a well-rounded system of academic and non-academic support that by nature creates the structure and culture which allows them to reach their full educational potential. Thus, making the collaboration between post-secondary institutions and community organizations vital to student success.
State Authorization Compliance Implications
While the benefits of holistic student support are clear, implementing such programs can prove to be challenging for higher education institutions. A major challenge is the potential for these services to cause state authorization compliance concerns. As leaders contemplate implementing these services, they too must consider the state authorization compliance foundational principle, which cautions that higher education institutions must obtain formal permission from a state to conduct specific activities within its borders.
Institutions located in one state that engage in partnerships with third-party servicers or community partners in another state, run the risk of triggering a physical presence (the measure by which a state defines the status of an educational institution’s presence within the state).
Because the guidelines of physical presence vary by state, state authorization compliance professionals must remain cognizant of each state’s metrics and common physical presence triggers.
Issues may arise with community partner programs if these entities are not cautious when marketing and advertising their services. For example, some state regulatory agencies have expressed concern about some community partners’ advertising language which alludes to an institution maintaining instructional sites or administrative offices in their state. Other regulatory concerns arise from the possibility of an institution employing faculty or staff in their state.
To ensure that your institution is taking all necessary steps to remain compliant, consider the following:
Review the regulations of the state where the institution offers the activity to determine if the activity causes the institution to be regulated in the state.
Remember, states vary as to which activities will cause regulatory oversight.
If you are a SARA participating institution, make certain to understand the definition of physical presence found in section 5.10 of the SARA Policy Manual
Obtain and document state approval from the state’s higher education agency.
Establish internal policies and procedures to remain current on state requirements and to maintain state approvals.
Remember, non-compliance with state authorization regulations can result in serious consequences for institutions. Penalties can include fines, loss of eligibility for federal financial aid, and the revocation of accreditation. It is therefore critical for institutions to ensure they remain compliant with each state’s regulations. Also, remember that the State Authorization Network (SAN) is the leader for guidance and support when navigating state and federal regulatory compliance for postsecondary institutions conducting out-of-state activities. Know that SAN is always here to help!
As we revealed in our recent post, ED’s New Proposed Regulations: Part 1, State Authorization Reciprocity, the Department of Education’s new package of proposed regulations includes issues that could have a big impact on institutions that offer programs in other states and upon the students they serve. While most press articles about the proposed rules focus on Gainful Employment, you will need to be aware of other nuanced issues also addressed in these proposed regulations that may have gone unnoticed during your first review. We are providing direction for you on very complicated sub-issues related to reciprocity and programs leading to a license or certification that are found in the Negotiated Rulemaking Issue, Certification Procedures. These important sub-issues aren’t the “sexy” regulatory issues getting most of the press coverage and could easily be overlooked.
It is important to reiterate that we support the consumer protection goals of the Department. We concur that it is very important to provide safeguards for students and protect the integrity of Title IV HEA programs. However, we do believe that in some circumstances there may be other ways to address the development of safeguards. This is especially true when there is a need to collaborate with state entities, such as state licensing boards, as partners to develop protections addressing programs leading to a state professional license or certification.
We encourage institution personnel to thoroughly review and discuss these additional proposed regulations to determine the impact on students at their institution. The Department invites the public to submit comments on the proposed regulations by the comment deadline of June 20, 2023. Additionally, the Department is seeking responses to directed questions posed throughout the preamble of the announcement for the proposed regulations. We will provide further information in this post on the process to submit comments. We encourage you to participate!
In Part I of our proposed regulations review, we offered the background on the rulemaking process and shared insight into the proposed regulations addressing reciprocity. Additionally, we offered background on the State Authorization Reciprocity Agreements (SARA) and the potential impact for institutions participating in SARA for purposes of state institutional approval for interstate distance education related activities.
Today, in Part II of our proposed regulations review, we will offer analysis of the proposed regulations addressing programs leading to a professional license or certification. This analysis will include background of the status of current regulations to then understand the new additional responsibilities including changes to the notifications. As with our previous post, to more easily read and direct you to specific regulatory language, we point you to specific pages of the unofficial version of the proposed regulations.
We know that these two posts are very dense. We hope that by indicating sections with sub-headings that you may review the information in bites. You may also wish to share these posts with colleagues to keep them informed about these issues that are not receiving much notice in the press, but may affect the institution’s work. Additionally, we hope that the information might help prepare you to develop your public comments.
Background on Federal Regulations for Programs Leading to a Professional License
State oversight varies widely by profession and state, but states have developed and maintain their own laws and regulations to protect the public and maintain the integrity of the licensed professions and occupations. Institutions are expected to follow all state requirements, as applicable, in the states where the student is located.
During the 2014 Department of Education Negotiated Rulemaking, the issue of Federal regulations for consumer protection for students enrolled in programs leading to a license was first addressed. The rulemaking committee did not reach consensus. Consensus means no opposition by the rulemaking committee members. Because the rulemaking committee did not reach consensus, the Department wrote the rules and released final regulations in December 2016. Among the regulations were required notifications for professional licensure programs completed solely through distance education, excluding internships and clinicals.
The effective date of these regulations was eventually delayed, then subject to a lawsuit, then became effective for thirteen months, and then replaced in July 2020 with the current regulations for notifications. Even with such drama, an important thing to note is that these 2016 regulations required public and individualized disclosures. Additionally, an important aspect that we greatly supported was that the institution was to obtain a written acknowledgement from a prospective student if the student received an individualized disclosure that the institution did not meet or had not made a determination whether the curriculum meets the prerequisites in the state of the student’s residence.
Please note that it was the Department that used the term “residence” rather than “location.” The terminology issue was corrected in the 2019 rulemaking.
The current Federal regulations, which came from consensus during the 2019 Department of Education Negotiated Rulemaking, expanded the notification requirement beyond “solely through distance education” to include all modalities, including in-person. The public notifications were also expanded to address all states and territories regardless of whether the institution was serving students in any additional states and territories.
For each state and territory, the institution is currently expected to provide public notifications to indicate whether the institution curriculum “meets,” “does not meet,” or “has made no determination” related to the state educational requirements to obtain a license. Additionally, the institution must provide individualized notifications to prospective and enrolled students under the prescribed circumstances. The regulations to provide these notifications became effective July 1, 2020. However, the written acknowledgement was not maintained.
What is now proposed?
The Certification Procedures issue is one of the five issues addressed in the newly proposed rule package. The items included in this issue are intended to address the process and criteria to go into a Program Participation Agreement (PPA), which an institutional leader signs to assure the Department that it will comply with the provisions of that Agreement to remain eligible to disburse Federal financial aid.
The Certification Procedures issue did not reach consensus during the Winter 2022 negotiated rulemaking. With no consensus, the Department wrote the proposed regulations for this issue and several others. As we mentioned in our previous post, these are proposed regulations which must be released as final regulations by November 1, 2023, in order for the regulations to become effective no earlier than July 1, 2024.
Institution responsibilities for programs leading to license, as proposed, include the following:
NEW! The institution “must determine” that the institution’s program “satisfies” educational prerequisites for professional licensure or certification where the student is located at the time of initial enrollment (p. 957-958) 34 CFR 668.14(b)(32).
REVISED! Public Notifications must include a list of all states where the institution is aware that the program does and does not meet such requirements (p. 981) 34 CFR 668.43(a)(5)(v).
You may be wondering if there are any proposed changes to the individualized notifications since the public notifications are proposed to indicate only “meet” or “does not meet” educational requirements. The individualized notifications were not addressed during the negotiated rulemaking process and there are no proposed amendments to the regulation offered. Therefore, the individualized notifications will remain the same as found in 34 CFR 668.43(c).
What is the Department’s reasoning for this proposal?
The Department shared on page 3 and on page 17 of the unofficial version of the announcement that the development of new regulations addressing Certification Procedures is to create a more rigorous process for certifying institutions to participate in Title IV HEA programs. The increased rigor is to protect the integrity of Title IV HEA programs and protect students from predatory and abusive behavior.
The announcement includes a quick summary of the proposed regulation subsection, 34 CFR 668.14(b)(32), on page 127. The summary indicates the following: “Amend § 668.14(b)(32) to require all programs that prepare students for occupations requiring programmatic accreditation or State licensure to meet those requirements and comply with all State consumer protection laws.” This language provides a concise statement to indicate institutions must determine if the program:
Is programmatically accredited, if required.
Satisfies all educational prerequisites for a professional license where the student is located (our issue of the day!).
Follows all consumer protection laws related to closure, recruitment, and misrepresentation.
We are very interested in the Department’s reasoning and concerns related to institutions satisfying state educational prerequisites for a professional license at time of initial enrollment, but found less development of rationale of this issue as compared to others in this proposed rule package. The announcement, on page 496, indicates the reasoning of this proposed language is that the Department is aware that institutions are enrolling students in programs that do not meet the educational requirements for a state license. The result, the Department shares, is that students are often left with difficulty finding employment and owing student loans for credentials that do not qualify them to work in the occupation for which they were educated. We agree that institutions should be following state requirements when applicable. We wonder if there is data addressing specific professions or regions to know the extent of student harm due to the institutions’ failures to meet applicable state requirements.
However, we are unclear about further analysis of this regulation subsection as described on page 780, which indicates the following: “On the first point, proposed § 668.14(b)(32) would make it harder for institutions to offer programs that lead to licensure or certification whose length far exceeds what is required to obtain the approvals necessary to work in that field in a student’s State.” The explanation continues to address overly long programs. We believe the Department may have conflated this issue with a previous subsection 668.14(b)(26) about the length of gainful employment programs leading to a license or certification.
A continuation of this possible conflation is found on page 784 when the Department indicates, “The proposed changes in § 668.14(b)(32) would provide benefits to students by reducing the likelihood of them paying more for education and training programs that artificially extend their program length beyond what is needed to earn the licensure or certification for which they are being prepared.” The proposed language of 668.14(b)(32) indicates meeting state educational prerequisites. We are not clear why the Department expressed that “§ 668.14(b)(32) would provide benefits to students byreducing the likelihood of them paying more for education and training programs that artificially extend their program length beyond what is needed to earn the licensure or certification for which they are being prepared.” This analysis by the Department does not seem to address satisfying state educational prerequisites.
We found no analysis addressing the language in the proposed regulation amendment to the public notifications in 34 CFR 668.43(a)(5)(v).
What Do These Proposed Responsibilities Mean and What are Our Concerns?
Institution must determine that the program satisfies educational prerequisites where the student is located at time of enrollment.
This increased responsibility requires the institution to meet a higher bar of compliance and go beyond notifications. The institution’s curriculum must now satisfy the state’s educational prerequisites in each state where the students are located at time of enrollment
Concern:
During rulemaking in Winter 2022, the Department’s proposed language indicated that the institution must “ensure” that each program “satisfies.” This new proposal replaces the word “ensure” with “determine.” We do not believe that the word “determine” is less of a legal burden than “ensure.”
In order for the institution to “determine” that the program “satisfies” educational prerequisites with any sort of legal certainty, we believe that the institution will need to seek affirmation from state licensing boards in each state that the institution is serving a student. We have learned through speaking with various national organizations of state licensing boards that professions and states vary widely. Professions in some states do not have an approval process for an out-of-state institution’s program to affirm satisfaction of educational requirements.
During rulemaking in Winter 2022, we provided a public comment during week one. We asked the Department if they had met with state licensing boards to learn of the process and structure for approvals for programs. We then offered to make some connections between Department staff and licensing board organizations or state agencies.
We also wonder about the Department’s view if the student changes location. It appears from the language of this proposed regulation that the responsibility to satisfy educational prerequisites is only based upon the location of the student at time of enrollment. Does this mean that the program is still eligible for Title IV aid if the student is no longer located in a state where the institution has determined that it satisfied educational prerequisites?
Public Notifications must include a list of all states where the institution is aware that the program does and does not meet such requirements.
This amended language appears to indicate that the institution’s responsibility would only be to list specific states for which they know the program “does” and “does not meet” state requirements due to the addition of the phrase “where the institution is aware”. It appears that a determination of each state and territory would no longer be required, as is currently required in regulation. The “no determination” option is proposed to be removed as an option for the public notifications.
Please note that there is no proposed amendment to the individualized notifications.
Concern:
This proposed language appears to lessen the institution’s public notifications to only the states where the institution has actual knowledge. This is different than the current regulations requiring institutions to address all states.
One may ask why the public notifications are necessary if the institution must determine that the program satisfies educational requirements in the state where the student is located at time of enrollment? Good question! There is no rationale offered for this amended language in the proposed regulations announcement, but we have a few thoughts.
The public notifications in this proposed form could provide notice to prospective students considering programs at various institutions. Additionally, the notifications could provide notice to enrolled students who may be considering a change of location. If a state is not listed in the public notifications, that is also notice to the students to be wary and ask questions about meeting requirements in states that are not listed.
The individualized notifications, however, should not be overlooked. The institution will remain responsible to prospective and enrolled students despite the institution’s responsibility to satisfy educational prerequisites where the student is located at time of enrollment. We wonder why the institution would accept a prospective student in a state where it does not satisfy educational prerequisites. However, it is reasonable to support an enrolled student with an individualized notification if the student is no longer located in the same state as at the time of initial enrollment.
Our Recommendations:
We maintain that an institution must follow all state laws and regulations in a state where the institution’s activities occur. If program approval is required in a state, we have always directed the institutions to obtain program approval in addition to state authorization to serve the students in a state. However, we are aware that not all states and professions maintain an approval process for the educational programs of out-of-state institutions. Although the state may have specific educational prerequisites for a license, the states themselves do not all have an approval mechanism to provide any legal certainty that a program satisfies educational prerequisites.
Additionally, we believe that there are reasonable motivations for a student to participate in a program from a state that does not satisfy all of the state educational prerequisites where the student is located at time of enrollment, for example, a:
Student may be located temporarily in a state attempting to pursue education while in the state (ex. active-duty military or military dependent),
Student may wish to obtain the education from a specific institution due to its strong reputation,
Student may wish to make the determination of location for employment based upon workforce needs after completion of the program,
Student may wish to obtain the first license in the state where the institution is located and then transfer the license through professional license compact and professional license reciprocity options,
Student may be aware that they can receive a provisional license in the state with time to complete the remaining state specific courses (ex. Teacher education licenses in some states).
In consideration of these motivations and the concern for the inability to obtain any legal certainty to determine that the program satisfies educational prerequisites, we offer the following recommendation.
The following recommendation was developed during the Winter 2022 rulemaking in collaboration with two negotiators representing consumer advocate groups and veterans. The two negotiators submitted this language during the third week of rulemaking and was met with interest by several other negotiators but was not approved at that time by the Department. We believe that we ran out of time for due consideration of this compromise that provides student protection and student flexibility. Subsection (iii) was added to be applicable to professional licensure programs.
Recommendation
(ii) Assess and satisfy the applicable educational prerequisites for professional licensure or certification requirements in the State, if such prerequisites are available or can be obtained from the State,
(iii) Institutions may make case-by-case exceptions to enroll students in a program that fails to meet the requirements of (i) and/or (ii) by obtaining the prior signed written consent of each student who opts to knowingly enroll in such programs and states their reason for their decision.
The rationale of this recommendation was to provide some flexibility when there is not an approval process in a state as not to limit students’ choices due to the state’s oversight mechanism. Additionally, the recommendation intended to revive the former requirement of a written acknowledgement by a student for instances of reasonable motivations to participate in a program even if the program does not satisfy educational prerequisites.
We additionally would like to see the U.S. Department of Education engage with entities that coordinate with or oversee professional licensing boards to better inform them of concerns and requirements and to seek collaboration with state licensure boards to ultimately better serve the education and training of future licensed practitioners.
How Can you Participate in This Rulemaking Process?
As mentioned earlier, we hope that you will consider submitting a public comment. It is important for the Department to hear from the practitioners implementing rules to obtain your feedback whether it is in support of the proposed regulations or providing recommendations or asking more questions. We hope that we have provided information pertinent to your work in order to assess the impact on your institution or agency.
Institutional personnel, program personnel, or individuals may comment. For an institutional or programmatic comment, you need to navigate the proper government relations channels at your institution. Issues that receive a greater volume of content tend to receive more attention.
The Department has expressed interest in public comments and is specifically seeking responses to the directed questions found within the body of the announcement for the proposed regulations. On page 38 of the announcement the Department directly invites the public to assist them in complying with the specific requirements of Executive Orders 12866 and 13563 and their overall requirement of reducing regulatory burden that might result from these proposed regulations. To that end, they request the following:
Please let us know of any further ways we could reduce potential costs or increase potential benefits while preserving the effective and efficient administration of the Department’s programs and activities.
The Department also welcomes comments on any alternative approaches to the subjects addressed in the proposed regulations.
We have seen the benefit of public comment to this Department on two very specific occasions in the last year. First, the Department indicated that they were persuaded by public comment about proposed regulations that appeared confusing regarding an amended definition of Distance Education. In this case, the Department responded by removing the amended language for the final regulations. Second, we have seen the Department actively responding with amended Third Party Servicer guidance due to the more than 1,100 public comments received. We appreciate the Department’s consideration of the view from the members of the public who are the key stakeholders in these issues.
This is your opportunity to tell your stories of student and institutional impact, ask clarifying questions, show support for the language, express challenges that could have unintentional consequences on students, or raise other concerns. You are urged to be positive and provide helpful suggestions.
Public comment submission process
The Department provides the following instructions:
Deadline to submit public comments is Tuesday, June 20, 2023.
Comments must be submitted via the Federal eRulemaking Portal at regulations.gov and accessible through the Federal Register Announcement.
Information on using regulations.gov, including instructions for finding a rule on the site and submitting comments, is available on the site under “FAQ.”
The Department will not accept comments submitted by fax or by email or comments submitted after the comment period closes.
Remember to include the Docket ID at the top of your comments: ED-2023-OPE-0089
If you require an accommodation or cannot otherwise submit your comments via regulations.gov, please contact one of the program contact persons listed in the announcement. For certification procedures the contact person is Vanessa Gomez. Telephone: (202) 453–6708. Email: Vanessa.Gomez@ed.gov.
What’s Next?
Stay tuned as SAN and WCET will continue to follow and update on this process. SAN developed a webpage, U.S. Department of Education Rulemaking 2021-2022 Information, that follows all of the steps related to this rulemaking including this most recent release of proposed rules. There you will find access to resources including previous posts capturing the development of the regulations.
We recognize that the concerns we raised came from a small subsection of an issue with big implications. This subsection is complicated and seems to be flying under the radar of many. We are providing our best understanding of the Department’s announcement and recognize that we are continuing to learn as well. We wanted to share our impressions to attempt to simplify your work to find the information you need. Don’t forget to examine this post and Part I to share with others at your institution or organization…and submit a comment!
We are considering publishing an additional post (Part III) with more information and/or other communications to members or the public to address a few more aspects of the proposed rules for which we are concerned are not getting enough review.
…..and we are all back in the States at our respective desks and ready respond to your questions and observations!
Big changes could be in store for institutions that offer programs in other states and for the students they serve. This might surprise you as recent press articles about the Department of Education’s new proposed regulations focused solely on Gainful Employment programs. Our readers need to know that the new package of proposed Federal regulations has significant reach beyond that one issue.
We understand and support the consumer protection goals that motivated additional safeguards for students and Federal financial aid investments. We believe there are better paths to implementing and expanding protections than what is proposed. Meanwhile, institutional personnel should learn about the proposed changes and be vocal in support or opposition of these pending requirements and inform the Department about the impact on their institution and students if implemented as written.
We will post two blog posts this week on these regulations. These posts will provide background on the rulemaking process, give our opinions on the impact of what is being proposed for state authorization reciprocity and for programs leading to professional licensure, inform you on the commenting process, and encourage you to participate. Your voice matters.
This first post covers:
Background of the Notice of Proposed Rulemaking,
Use of the Program Participation Agreement to implement the rules.
The reasoning behind the proposed rules,
Next steps in the rulemaking process.
Background on proposed rules and their impact on state authorization reciprocity,
Which state laws are now subject to SARA?,
What changes are proposed?,
Our predictions of what would happen if enacted,
Our recommendations.
Members should prepare to comment.
Background on the New Notice of Proposed Rulemaking
In late 2021 and into early 2022, the Department of Education held a Negotiated Rulemaking process that included several higher education issues around “institutional and programmatic eligibility” for federal financial aid. As a result of negotiations, the Department released a set of proposed regulations for comment. After responding to those comments, the Department can release final regulations and set an implementation date.
Immediately after the release last week, we alerted WCET and SAN members via email about two proposals under the “Certification Procedures” issue. Included are two proposals that are of particular interest to those at institutions serving students in other states, whether through distance education or in-person:
Programs leading to professional licensure must “satisfy” the educational prerequisites for professional licensure or certification in that state where the student is located.
Institutions using state authorization reciprocity will be affected by the expectation that they comply “with all State consumer protection laws related to closure, recruitment, and misrepresentations, including both generally applicable State laws and those specific to educational institutions.”
These two issues are extremely easy to miss as they are buried in the unobvious “Certification Procedures” section, and they have received little notice in the press or by higher education organizations. We will get to the particulars of each of those proposals later in these blog posts.
How Are They Planning to Implement the Proposal?
SAN and WCET have been closely following those issues since they were first proposed in the “Certification Procedures” issue in rulemaking last year. The idea is to add this new language to the Department’s Program Participation Agreement (PPA). ” The PPA sets the conditions for “the initial and continued participation of an eligible institution in any Title IV, HEA program upon compliance with the provisions…” of the agreement. By signing, institutional leadership asserts that the college or university agrees to abide by the detailed conditions so as to remain eligible to disburse Federal financial aid.
Why Did They Make These Proposals?
The proposals are based on concerns about protecting students as consumers and to assure that Department of Education financial aid investments are sound.
For professional licensure, they say: “We are aware of institutions enrolling students in programs that do not meet such requirements. Students in these programs often find themselves struggling to find employment and owing student loans on credentials that do not qualify them to work in the occupations for which they were trained“ (page 496 of the unofficial version. Note that we reference the unofficial version because it is easier to read and to reference by page number).
For reciprocity, they say: “We are concerned about past situations in which States have raised concerns about institutions that are physically located outside of its borders and taking advantage of students while the State is limited in its ability to apply its own consumer protection laws in these areas to protect its residents” (page 497-498).
It would be interesting to have data about the extent of these concerns and how often they happened overall and, for reciprocity purposes, with SARA-participating institutions.
What Are Next Steps?
Remember that these are proposed rules and are not yet effective. In brief, next steps include:
The Department will accept comments until Tuesday, June 20. Anyone may comment. We encourage anyone who supports or decries a proposal to participate. The Department is especially interested in hearing about the impact on institutions and students. We will give you more details on how to comment in the next post.
The Department will review and create responses to all the comments. As a result, they may make some changes to the final language.
The Department will release final language with its reaction to the comments, changes it made, and a timeline for implementation. If they release the final rules by November 1 of this year, they could become effective as early as July 1, 2024.
Meanwhile, you should probably start thinking about what you and your institution would do if this were to become effective in the summer of next year. Remember that volume matters. The more than 1,100 comments on Third-Party Servicers made a difference.
State Authorization Reciprocity – Background and Proposal
Dictionary.com defines “reciprocity” as “the relation or policy in commercial dealings between countries by which corresponding advantages or privileges are granted by each country to the citizens of the other.” While there could be multiple agreements for state authorization reciprocity, the big player is the State Authorization Reciprocity Agreement (SARA). By joining SARA, its members (49 states, DC, Puerto Rico, and the Virgin Islands) have voluntarily agreed to a standard set of regulatory requirements and to acknowledge the institutional recognition granted by another member. That recognition is limited to conducting distance education and additional enumerated activities (e.g., marketing, limited in-person instruction, practical experiences) in member states. For most states, its path to becoming a member of SARA required a bill to be passed by the legislature and signed by the governor. It is a voluntary process that required much thought and work in each state.
SARA and the Applicability of State Laws
For out-of-state institutions operating in a SARA member state, territory, or the District, those governments have agreed that they will follow SARA policies in recognizing and overseeing those colleges and universities. The state where the student is located may also enforce other rules not included in the SARA agreement, such as requirements overseen by other state agencies, such as for professional licensure programs, and enforcement of “general purpose” laws. Those “general purpose” laws include laws that any business would need to follow, such as conducting fraud or misrepresentation in dealing with customers…or, for institutions, students.
“An agreement between two or more States that authorizes an institution located and legally authorized in a State covered by the agreement to provide postsecondary education through distance education or correspondence courses to students located in other States covered by the agreement and cannot prohibit any member State of the agreement from enforcing its own general-purpose State laws and regulations outside of the State authorization of distance education.”
A Change to the Applicability of State Laws is Being Proposed
The new language proposed by the Department of Education (page 957-958) states:
“(32) In each State in which the institution is located or in which students enrolled by the institution is located, as determined at the time of initial enrollment in accordance with 34 CFR 600.9(c)(2), the institution must determine that each program eligible for title IV, HEA program funds-… …(iii) Complies with all State consumer protection laws related to closure, recruitment, and misrepresentations, including both generally applicable State laws and those specific to educational institutions.”
During negotiated rulemaking talks last year, representatives of consumer protection groups sought to allow each state to be able to enforce ANY laws specific to educational institutions. They suggested that the benefits that would remain for those participating in reciprocity are a common application and common fee. We believe the Department staff heard the concerns and suggestions of those groups.
If implemented as they suggested last year, it would not have officially ended reciprocity, but it would have severely lessened the value of participating in SARA. We liken it to having a driver’s license, except instead of zooming across the border at 75, you have to stop, take an eye exam, pay a fee, and pass a quick test..and what happens at those border checks would vary each time you crossed state lines
We believe that the Department was trying to seek a compromise. They proposed limiting the expansion of the applicability of laws specific to institutions to “closure, recruitment, and misrepresentations” as a way to expand consumer protections while still preserving more elements of reciprocity. One piece of evidence that the Department wishes to limit the impact is that the Department suggests (page 498) this change would NOT include “tuition refund policies, rules on site visits, and State-specific outcomes metrics.” They also allude to this compromise as they solicit comments giving feedback by saying (page 499):
“Therefore, we seek feedback on the best way to construct this requirement so that students are protected, financially and otherwise, without creating unnecessary burden on institutions.”
We are heartened to see the attempt at compromise. It is a worthy goal to find a way to expand student consumer protections even if it means a slightly less robust version of reciprocity. As long as it does not leave only a shell of reciprocity.
State Authorization Reciprocity – Our Analysis and Possible Comments You Might Make
In this section, we will give you observations on the proposed language and give our readers some ideas about comments that you might wish to make. Remember that comments are strongest if you reflect your support or concerns based upon experiences that you can share. Below are our questions…
Will This Proposal Survive Legal Challenges?
Now, we hate to applaud compromise and then turn immediately to the antithesis of cooperation – legal action. But we feel we must.
In the United States, higher education is under the purview of the states. SARA is a state-to-state agreement. While federal financial aid is run by the U.S. Department of Education, can it actually use the backdoor of institutional eligibility to force the states to change? This is both a legal and political issue.
It’s a technical issue, but the state authorization and transcript withholding proposals were both raised during the second session of the rulemaking committee, well after the agenda was set for the rulemaking panel. Typically, the agenda is frozen at the first meeting. The Department and facilitator even warned negotiators to stop raising new topics, but they did anyway.
There are two other technical issues in which this proposed requirement is at odds with other state authorization regulations from the Department:
The proposed requirement conflicts with Department’s own definition of “state authorization reciprocity agreement” (Chapter 34, § 600.2) that we cited above. It’s an easy fix, but we know that the Department has four wildly definitions (we found three in this WCET analysis and forgot about “clock hour” as a fourth) of “distance education.” We do not want to see the practice of multiple definitions repeated here if their goal is understanding and compliance by institutional personnel.
The proposed “at the time of enrollment” language conflicts with the Department’s regulatory section on state authorization (Chapter 34, § 600.9(c)(2)(iii)). In that section, institutions also must act if “the student’s location has changed to another State.”
If this proposal is legally tenuous, actively working on a compromise with SARA might be a better path. More on that later.
How and Who Will Interpret the Meaning of “Closure, Recruitment, and Misrepresentations”?
So…this question arises from WCET as an organization that has been trying to interpret (with only partial success) the term “regular and substantive interaction” since 1992. WCET and SAN members have similar fears for the words “closure, recruitment, and misrepresentations.”
If left as they are, who interprets these terms? We are feeling déjà vu with the recent “Third-Party Servicers” guidance where it appeared the language was clear to the Department, but was not clear to anyone else.
If interpretation is left to each State, there will be a crazy patchwork and for some states the number of laws that could be included for reciprocity-participating institutions could be massive and could be minimal for others. It would be better if the same requirements were common across all states. Otherwise, we would be driving back towards uneven consumer protections and much time could be spent in discussing what the rights of each state are.
Taking an initial try at defining what additional rules states might consider as being relevant “State consumer protection laws” and thus subject to the variable application of this proposed rules in each State leads us to this list:
Closure
Contributing to tuition recovery funds,
Submitting to institutional surety bonds,
State catastrophic event policies,
Records retention processes,
Teach-out process.
Recruitment
Marketing requirements and restrictions.
Advertising requirements and restrictions.
The need to register recruiters or staff who physically appear in a state.
Certain requirements for staff or faculty residing or present in a state.
Physical presence requirements.
This may also have a detrimental effect on a student who moves from state to state. For example, a student moves to a state where the institution no longer enrolls students due to additional compliance requirements of that state. Regulators in other states often are willing to grant exceptions for “one-off” situations, but that becomes more difficult when needing to obtain that exception from multiple state agencies. As a result, the student may need to discontinue enrollment at the institution.
In the reasoning for adding their proposal, the Department focuses (497-498) on “tuition recovery funds” in which institutions pay a portion of their income to cover losses to students at institutions that close. A quick review shows that about 10 states have tuition recovery funds and another six have such funds for a subset of institutions. If implemented, in the future institutions would have to contribute to the fund in each of those states in which it wishes to recruit or enroll students. A proposal to add a tuition recovery fund requirement in the current SARA Policy Modification Process would collect 0.25% of all institutional income from SARA enrollments. Some state-based tuition recovery funds collect a much higher rate of tuition and fees for students enrolled in that state.
Finally, for misrepresentation, we are surprised by this one. Through SARA, states are already able to enforce fraud and misrepresentation rules on SARA-participating institutions. There have been those in some of the consumer protection groups who have, themselves, misrepresented this point. We are at a loss at to what adding this term adds to protections. Perhaps it is here to guard against other reciprocity agreements that do not address misrepresentation?
Our Predictions on What Would Happen If the Proposal is Implemented
The Department wishes feedback on how to expand consumer protections “without creating unnecessary burdens on institutions. We will start with the latter and end with our consumer protection recommendations.
We predict that:
Without further clarification, some states will take great latitude in trying to fit every regulation they can into one of the “closure, recruiting, or misrepresentation” buckets.
Meanwhile, other states will continue to underperform in student protections. This is true with or without SARA, but SARA raised the bar for many of these states and it does not get sufficient credit for that.
Institutions will cease accepting students from some states. The cost of compliance and compliance staffing will simply be too high. The accompanying professional licensure proposal will hasten that retreat from some states.
With less competition in some states, the beneficiaries will be the remaining for-profit institutions and the large public and non-profit colleges and universities. We doubt that enriching these institutions was a desired outcome of the proposal.
Our Take on State Authorization and Our Recommendations
We applaud the intent to compromise, but think it lands short of doing the hard work to expand consumer protections in a much more meaningful way. We make a couple recommendations below.
Very Specifically Define the Terms
We believe the phrase “closure, recruitment, and misrepresentations” has the nugget of a good idea, but this particular choice of words is far too broad. Those words leave too much to interpretation. And unevenness in interpretation by states will undermine reciprocity and leave students with uneven protection.
We also believe that leaving the terms broadly or undefined could lead to some unexpected outcomes in some states. First, it is rarely stated that some forms of “protection” are actually “protectionism” serving as methods for eliminating out-of-state competition. Additionally, given the current political climate, the term “recruitment” could be weaponized. For example, one state may introduce a rule disallowing any mention of diversity, equity, and inclusion by institutions serving its citizens. Another state may require culturally-sensitive content and the use of chosen pronouns by faculty. We do not wish to explore the culture or moral underpinnings of those suggestions, but states are in very different places on these matters.
Instead, if the Department wishes to continue down this path, we suggest a limited set of definitive terms that narrowly target common consumer protection problems witnessed in both in-person and distance education. Here are some concepts that could be expanded:
Truth in advertising and truth in marketing requirements.
Prohibitions against high pressure sales.
Prohibitions against recruiters being paid on a per student basis.
A tuition recovery fund or institutional surety bond, but not both.
Be Brave and Expand Certain Consumer Protections to ALL Students
Alternative to the above recommendation, we pose an audacious challenge with broader impact.
A major problem with what the Department is suggesting is that consumer protection will be dependent on the state in which the student is located. The critics of SARA often condemn it as creating a two-tiered set of student protections. We fail to see how a 52-tiered (the 49 states plus 3 other governmental entities that are SARA members) set of consumer protections is a better option.
Additionally, the actual benefits provided by existing state tuition reimbursement programs are variable. The Institute for College Access & Success (TICAS) is a consumer advocacy group) that reviewed California’s Student Tuition Recovery Fund (STRF). They found that: “Unfortunately, thus far STRF has only provided financial relief to a relatively small number of students affected by school failure. While STRF has the potential to be a critical resource for California students harmed by failing schools, it is clear that improvements to visibility and accessibility to students are needed in order to accomplish that goal.”
Therefore, we challenge the Department to work with SARA (the regional compacts and NC-SARA) and us (SAN and WCET) in creating a national review to plan how reciprocity can best include a program for tuition recovery fund or an institutional surety bond. Note this would not be a federal program, but one that would be part of a state-to-state agreement with broad coverage among the member states.
Simply put, ALL STUDENTS SHOULD HAVE EQUAL PROTECTION. What is proposed falls far short.
Before the Department’s recommendation was made, we commented on a proposal from several of the consumer protection organizations for “Protecting Students from Abrupt Closures” as part of the SARA Policy Modification process. The consumer protection groups proposed a single tuition recovery fund to be operated by SARA.
In our response, we concurred that they are on the right track, but observed that “what they proposed is far from a complete, implementable proposal.” We raised a host of legal and operational questions that need to be considered in implementing either a single tuition recovery fund or surety bonding requirement. Alternatively, SARA could require its member states to meet minimum requirements for a tuition recovery fund or surety bond.
This will be hard. This will take time. It can be done.
Russ was on the first two committees that led to the creation of SARA and we were hopeful of getting 15 states involved. Cheryl made the State Authorization Network what it is today. Both tasks were impossible, but we should not shy away from doing the impossible. Let’s protect more students.
What the Department can do is help and be part of the solution.
What’s Next?
Stay tuned for our next blog post. In that one we will cover:
Another Departmental proposal regarding programs that lead to professional licensure, in which that recommend that “the institution must determine” that each program eligible for Title IV, satisfies the educational prerequisites for professional licensure or certification in that state.” (Bold added, see page 957-958).
Why and how you should submit a comment to the Department.
Meanwhile, we hope that you examine this post, talk to others at your institution or organization…and submit a comment.
…oh yes, did we tell you that the rulemaking document was 1,077 pages long and that Cheryl was on vacation in England when it came out?
Let us know if you have questions or observations.
Did you know that May is Mental Health Awareness month?
According to the National Alliance on Mental Illness (NAMI), the U.S. has observed this since 1949. The month is a focused “national movement to raise awareness about mental health.” You can learn more about the movement on the Mental Health Awareness Month website. Mental Health and wellness impacts us all in many ways, both personally and professionally.
When you think about personal or professional wellness, what enters your mind?
Here are some of the words that pop into my head:
Self-care.
Work-life balance.
Wellness.
Well-being.
Intention.
Mindfulness.
Authentic Self.
Grace.
Health.
Healthy lifestyle.
Relaxation.
Happy.
Positivity.
Mental health.
Emotional health.
Fitness.
Strength.
Adaptability.
Resiliency.
I have been thinking about this a lot over the past few years. As I’m sure you remember, the COVID-19 pandemic changed our world in many (many!) ways. One of the bigger ways – a new focus on work and life-balance and wellness.
Where will this focus take us? Can we orient toward a professional environment that prioritizes the mental and physical health and well-being of staff but also ensures we meet our productivity goals? I believe we can. And, apparently, so do many of our colleagues in the WCET and higher education community.
That’s why WCET selected the topic of Leadership and Wellness for the month of May. To me, having strong, adaptable, and resilient team members means we accomplish some amazing work in our planned timeframes. However, without healthy team members, deadlines are missed, or mistakes are made.
What do people want when it comes to work-life balance?
Cindi Fukami, a professor in the Daniels College of Business at the University of Denver, has said that the need for work-life balance isn’t new.
But COVID “accelerated this trend and the conflict between work and life demands was front and center.”
The U.S., unfortunately, seems to outpace other nations in hours worked per week and employees have less vacation time and fewer benefits for working parents.
Fukami advised that people just want a “productive life along with a productive work life” (Ballard, 2022).
Why should we prioritize this?
The Great Resignation highlighted a voluntary and mass exodus of workers associated with the pandemic, yes, but there are deeper issues at play. Studies suggest that the trend of leaving jobs that didn’t offer exactly what employees want out of their work and their life, was happening before the pandemic. COVID just pushed it over the edge a bit.
More experienced workers used employment changes due to the pandemic as a time to retire.
Younger employees saw the potential impact of the pandemic on their life and health and decided they “have one life to live and they want to live it to the fullest.” That usually doesn’t include staying at a job that doesn’t make them happy or matter to them (Phipps, 2022).
Lack of benefits are often cited as reasons people quit a job. These can include:
Low pay,
Lack of advancement opportunity,
Feeling disrespected at work,
Childcare issues (many of which continue still),
Lack of flexible hours or choice of hours,
Lack or poor health insurance and paid time off (Phipps, 2022).
Simone Phipps, professor of management at Middle Georgia State University, offers that employers must focus on employee wellbeing and listen to what their staff tell them they need. By modeling wellness, boundary setting, and balance as a leader, team members begin to adopt these healthy behaviors. In turn, they become more productive, more creative, and more collaborative. I love that Dr. Phipps and others have said that we all need to focus on our “shared humanity” when it comes to navigating this new way of living.
Our Theme this Month
As I said, our theme this month is Leadership and Wellness.
To help you consider your own personal wellness and the wellness of your team (whether you are in a leadership position or just want to help role model wellbeing in the workplace for your peers), WCET will offer resources and events in this topic area.
May Closer Look – releasing next week via wcetNEWS, our WCET Member-only Closer Look will be on Leadership Tips for Balancing Wellness and Supporting Your Team.
We hope you’ll join us in honoring May as Mental Health Awareness month by learning new ways to focus on your own well-being and perhaps help your colleagues as well.
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