Author: Lindsey Downs

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Assessment and evaluation of microcredentials: What success looks like and to whom

Post author By Lindsey Downs
Post date September 29, 2022

Overview and Introduction

Today, we conclude the WCET blog series on microcredentials which set out to address the inception, implementation, and evaluation of microcredentialing approaches across the higher education industry. We learned that there is a wide range of reasons for an institution to begin a microcredential initiative, an even broader spectrum of microcredential terminology, and yet two primary outcomes: “to improve student recruitment and retention” and “to align learning with shorter-term outcomes that can more immediately align with career progression” (Niles and Lazarewicz, 2022). Institutions and training providers use microcredentials to adapt to a number of trends such as decreasing student enrollment and workforce degree requirements and increasing acceptance of online learning, employer demand for skills training, and public demand for greater return on educational investment (Higher Learning Commission, 2022). As professionally trained and former instructional designers, we begin by defining what success looks like. In this blog post, we will present what we learned about how to assess and evaluate the efficacy of microcredentialing approaches through a variety of stakeholder perspectives.

Multiple Perspectives on Success

“One of the positives from the pandemic has been the acceleration of innovation and change in higher education – microcredentials have grown in scale and areas of focus to help provide current students or adult learners additional knowledge to help them be more competitive in the job market. The assessment and evaluation of whether these microcredentials are making a difference for students and adult learners and whether employers value these micro credentials. The next phase of the growing area of microcredentials should seek to answer the questions about employer value, industry microcredentials, or higher ed developed micro credentials, measuring learning outcomes, and more,” shared Melissa Vito, Vice Provost of Academic Innovation at the University of Texas at San Antonio.

Key questions: Key Questions: What does success look like for students, employers, faculty, and administrators? What are the needs that institutions can help learners and employers to fill, in terms of gaps in the curriculum for learners to gain more marketable skills and be competitive in the marketplace? What are the hidden needs that employers have not recognized but that institutions can identify through the work of their faculty as experts in the field? Who are the stakeholders that should be included in the microcredentialing process, and how should institutions build a strong governance model? How can microcredentialing programs be intentionally and strategically integrated in the curriculum design processes?

Microcredentials should create positive labor market outcomes in terms of employment and earnings. “If done correctly, microcredentials help students develop skills that today’s employers are expecting from their entry-level talent” stated Scott Shireman, Global Head of Coursera for Campus. “When microcredentials are built and recognized by industry leaders like Google, IBM, and Meta, they reflect the skills and tools most in-demand by top employers.” Shireman also invited us to consider how microcredentials impact students. “From a student recruitment perspective, the fact is that students today, and their parents for that matter, are thinking more critically about the ROI of the traditional four-year degree. We’re seeing that shift in mindset reflected in university recruitment numbers. It’s a very competitive landscape, and universities are increasingly leveraging microcredentials and job-relevant skills training to differentiate their brand and show students that they’ll benefit from multiple signals in a competitive and fast-evolving market – the two or four-year degree they graduate with, and the career certificates they earn along the way.” The new Coursera survey published shows high demand for industry microcredentials from students and employers in tight labor market.

Kate Smith, President of Rio Salado College, reinforced that student success is at the core of an effective microcredential: “Evaluation of microcredentials is tied to outcomes of students – retention, completion, post-completion employment, and wages, along with structured qualitative feedback from learners, employers, and related faculty and staff.” Microcredentials can provide students with early exposure to career choices, helping students to “build confidence to continue their post-secondary education” and also to reinforce or redirect career choices.

For former Mesa Community College student, Sam McFadden, a two-week, full-time “wire harness bootcamp quite literally changed my life, and has put me in a position to be successful in my career, and complete my education. Three years ago, it would have been difficult to imagine that I would be where I am today.” Today, Sam is employed by Boeing, the world’s largest aerospace company.

Jude Chudi Okpala, Professor of Instruction at the Department of Philosophy and Classics at The University of Texas at San Antonio explained what success should look like for students. “Success in a critical thinking microcredential, for example, consists in application of critical thinking on a concrete and real problem. Looking at students’ work in such microcredentials, one sees a correspondence between the objectives and the learning outcomes for the microcredential: for example, evidence of logic in addition to effective understanding of complexity and the relationship between the problem and solution. Invariably, a successful microcredential in critical thinking should reveal independent thinking and the students’ ability to solve a concrete problem. The microcredential should demonstrate without ambiguity the students’ skill in critical thinking/problem-solving.”

Lisa Larson, President of Eastern Maine Community College, Ed Design Lab, Designer in Residence believes “micropathways are the gateway to transformation” because this demonstrates “we are committed to transforming our institution to meet the needs of those who need us most.” Larson emphasized the need to measure the engagement, student and employer value proposition, and impact after completion. For example, getting employers to include microcredentials in their recruitment, hiring, and promotion practices are metrics of success. In short, Larson asks “Who did the microcredential make a difference for, and how can we tell the story of impact?” Microcredentials may also increase access for non-traditional students to “break through ceilings” and “earn a living wage” contributing to equity and economic growth in our communities. Larson advised that microcredentials should be “digitally discoverable”, so students can “own the learning upon receiving validation of the competency and skill.” The digital nature of a microcredential should “create the visibility for students to take every ounce of learning and experience with them.”

Assessment and Evaluation

“Ideally a feasibility study includes a market review of demand, wages, stakeholders, and resources needed to build and implement the credential, combined with a SWOT analysis. The microcredentials are then developed with input and co-design principles when feasible, with local or national industry partners” (Kate Smith, 2022, personal communication). Data analysis plays a key role in evaluating the effectiveness and impact of scope, resources, risks and feasibility of a microcredential project. Consensus-building with campus stakeholders and employer stakeholders is critical to a mutual definition of what success looks like.

Key Questions: How do we measure the efficacy of microcredentials in this evolving landscape? What are the standards that institutions, employers, faculty, and learners need to agree upon to create transparent and relevant pathways for career? How will competencies and skills be assessed and validated by both institutions and employers? How will the institution and student signal the completion of the microcredential? How can the evaluation process drive a cycle of continuous improvement to generate microcredentialing programs that are up-to-date and aligned to the market needs?

Lydia Riley, Chief of Staff of The University of Texas System (UT System) invites institutions to consider the “AGILE planning framework with frequent feedback loops that lay out the foundations of the microcredential programs, identifying strategic goals for revenue-generation or mission-enhancing endeavors”. All stakeholders expressed a desire for marketable skills, relevant, contextualized curriculum, and increased perspective of employers into curriculum. While success may be measured by the value proposition to learners, the microcredential must also be validated by employers. One of the most challenging elements when planning and assessing microcredential approaches “is the personnel capacity and stakeholder capacity; the people on the ground really designing and implementing into the institutional structures” (Lisa Larson, 2022, personal communication).

Leah Palmer, Executive Director at Maricopa Community Colleges Arizona Advanced Manufacturing Institute (AzAMI) emphasized the importance of data tracking and benchmark metrics to measure the impact on student success, costs to the institution, and sector demands for talents. Palmer recommends tracking the number of hits on your microcredential webpage, enrollments and trajectory, value propositions such as course completions, earned badges or certifications, and follow-up emails for employment-related status. We must create opportunities for enhancement and/or implementation of corrective actions during the microcredentials planning phase.

Micheal Voss, Dean of Instruction at Mesa Community College recommends an “annual threshold review of Key Performance Indicators (KPIs) and a more robust program review at least every 5 years. Ideally, program completers should receive follow-up surveys 12-18 months post-completion to gain feedback as to how the knowledge, skills, and behaviors learned have impacted the person’s employment or next step education status.”

Lori Lindenberg, District Director of Data Analytics and Strategy at Maricopa Community Colleges explained how their system of 10-independently accredited colleges shares data through the Student Clearinghouse Postsecondary Data Partnership (PDP) to assess the leading and lagging indicators typically associated with the guided pathways framework, such as credit momentum and time to completion. Measuring economic outcomes has proven a little harder for some institutions. Employment data is notoriously difficult to acquire yet increasingly important to track the impact of microcredentialing. Maricopa Community Colleges has a partnership with Equifax to study wage data (pre- and post-completion), annually for up to 10-years, but this has been traditionally focused on degrees and certificates. They are working to transcribe recognition of microcredentials into their student information system and also experiment with digital badging platforms. The country’s largest accreditor, the Higher Learning Commission, sees an opportunity to provide a quality assurance service for non-degree credentials, yet they note their current limitations in capacity and scope (HLC, 2022). Perhaps third-party validation will promote shared standards of quality and transferability of microcredentials.

Key Takeaways and Summary Points

Through the testimonies and insights gathered in this process, we have identified that different data points will be indicators of success based on stakeholder perspectives (Larson, personal communication, 2022). Institutions and employers should base their microcredential partnership on key values and standards such as transparency, validation, recognition, and reward of skills. Table 1 illustrates this point that the measures of success may be complex and individually defined. The value proposition of a microcredential often depends on one’s perspective. 

Table 1. What success looks like by stakeholder group – words commonly used

Student Employer Faculty Administration Accreditor
Affordable Meet a specific workplace need that directly support industry job roles and job descriptions that are in demand Engagement Meet a specific workforce development need Quality assurance
Short-term Recruit skilled workforce  Learning  Student’s success Curricular alignment
Re-careering Diversity equity and inclusion strategies for recruitment Authentic assessment Enrollment Employability of graduates
Upskilling Retain and reskill/upskill current employees Retention  Retention Transparency of tuition, fees, and costs
Recognition of skills  Career pathways Completion Complete ROI for students
Career progression   On-ramps to educational pathways Completion  
Higher wages   Off-ramps to employment Revenue  
New job or different job   Stackable educational and career pathways Digitally discoverable  
Pathways to economic self-sufficiency   Curricular alignment to employment Portable for the learner  
Gain more confidence in career path and future   Career-ready Valuable to the learner   
Confidence to continue engaging in post-secondary education   Industry engagement and advisory Validated by the employer  
Effective demonstration of the target skills     Equity opportunities for students   
Authentic alignment of the learning objectives and outcomes     Community engagement  
Understanding of how to apply the skills        
Reflection on acquired competence and its corresponding outcomes–what the students should be able to do        
Concrete professional growth        
Relevance of the assessment and partnership with the industry/community        

It became quite evident that assessing and evaluating microcredentials will require rapid prototyping with inclusive feedback loops from students, faculty and employers. Microcredentials have shorter lifecycles and therefore continuous evaluation of KPIs and lead measures are critical. Table 2 shares examples of different KPIs for assessing and evaluating microcredentials that align to the ADDIE instructional design process.

Table 2. Key Performance Indicators to assess along the microcredential lifecycle 

Needs Analysis Design & Development Implementation Evaluation
Institutional capacity  Stakeholder buy-in Time-to-market Student surveys
Personnel capacity Employer engagement Minimally viable product  
Feasibility analysis Co-design between institutions and employers Marketing leads Student completion 
SWOT analysis Standards  Enrollments Student intent fulfilled
Identification of skills gaps Signaling completion Alignment to industry jobs Feedback about the positive outcomes of the microcredential
Technology needs   Transparency, validation, recognition and reward of skills Employment opportunities
      Revenue generation
      How and where the student shares the microcredential
      Employer integrates into recruitment, hiring, retention, and promotion processes
      Content quality 
      Improve the design of the credential

Contributors

A heartfelt thank you to all the expert interviewees lending their time, leading this transformative movement in higher education, designing these critical learning experiences, and for helping us to measure what matters most. Interviewees included:

  • Dr. Lisa Larson, President of Eastern Maine Community College, Ed Design Lab, Designer in Residence
  • Lori Lindenberg, District Director of Data Analytics and Strategy – Maricopa Community Colleges
  • Dr. Jude Chudi Okpala, Professor of Instruction- Department of Philosophy and Classics – The University of Texas at San Antonio
  • Leah Palmer, Executive Director – Arizona Advanced Manufacturing Institute (AzAMI) – Maricopa Community Colleges
  • Lydia Riley, Chief of Staff – The University of Texas System
  • Scott Shireman, Global Head of Coursera for Campus
  • Dr. Kate Smith, President – Rio Salado College- Maricopa Community Colleges
  • Dr. Melissa Vito, Vice Provost of Academic Innovation – The University of Texas at San Antonio
  • Michael Voss, Dean of Instruction – Mesa Community College – Maricopa Community Colleges

References:

Higher Learning Commission. (2022, April). Evolving: Accreditation and credential landscape. Retrieved on September 20, 2022 from https://download.hlcommission.org/initiatives/2022StakeholdersRoundtablePapers.pdf

Lazarewicz, K., Niles, G. (2022, May 26). Considering Your “Why”- How Developing a Microcredential Strategy Will Help Your Students (and Your University) Thrive. WCET Frontiers. https://wcet.wiche.edu/frontiers/2022/05/26/how-developing-a-microcredential-strategy-will-help-your-students-and-your-university-thrive/  

Shireman, S. (2022, September 27). New Coursera survey shows high demand for industry microcredentials from students and employers in tight labor market. Coursera Blog. https://blog.coursera.org/from-higher-education-to-employment/

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Lessons Learned – The Implementation Stage of Microcredentials

Post author By Lindsey Downs
Post date September 22, 2022

Welcome to the continuation of the WCET + WCET Steering work group series focused on microcredential initiatives. This series explores microcredential adoption, implementation, and evaluation. Previously, the series has reviewed the importance of understanding the strategic goals of microcredential projects, the value that clarity of terms plays in an emergent area, and considered the inception of a microcredential project.

With today’s post, our steering committee work group discusses the implementation stage of a microcredentialling program. The authors call upon several experts in the field to share lessons learned from their experiences implementing microcredential programming at their institution.

Thank you to those interviewed and the WCET Steering Committee working group for this outstanding series!

Enjoy the read,

Lindsey Downs, WCET

Launching or growing a mircocredential program requires coordination and thoughtful planning. Luckily there are others who have traveled this path before you and the microcredential community is one that is happy to share their lessons with others. 

Key aspects of a successful implementation include: 

  • Creating a framework and process that can meet your needs today and into the future.
  • Building a structure for the stakeholders to have a voice in the development and management of a program.
  • Making sure your policies are built to uphold the integrity of your work and your institutional value.

To better highlight the implementation phase of a microcredential program, we drew upon the expertise of four talented and engaged members of the WCET community to share their experience and wisdom. 

Q&A With Experts

Please note, some responses have been edited for space and clarity.

Q: Why did you start your microcredential program? Did you have a specific purpose or reason for starting?

Jennifer Dale, Community College of Aurora:

Jennifer Dale photo - young blond woman with glasses, smiling.

We want to be an agent of change for students’ social and economic mobility.

Microcredentialing allows students to access the key skills and content knowledge to enter into their field faster, at a higher earning potential, and with the option of returning to stack their credentials further to advance intheir respective roles. 

Lesley Voigt, Madison College:

Lesley Voigt - young woman with brown hair smiles at the camera.

We brought micro-credentials to campus in 2012 as a way to help validate and verify the learning that takes place within our Continuing Education courses.

We were hearing far too often that our earners as well as our/their employers wanted something more than just an “S” or a “U” on a transcript. Building out credentials that required some sort of assessment helped the badge consumers verify that knowledge transfer took place. 

Mark Hobson, SNHU:

During the redevelopment of our MBA program content, we determined industry recognized credentials are a high-value proposition to reinforce program content and for the career development of learners. We selected a program partner, Wiley, to produce and deliver these credentials that had a business partnership with Association of International Certified Professional Accountants (AICPA).

We asked for credentials to cover technical, managerial and leadership skills. Two graded credentials are included in every course and an option for about 20 other valuable credentials. The credentials skills such as MS Excel, PowerBI, Coaching and Mentoring, Critical Thinking, Project Management and more The reasonable cost of the credentials ($30.00 each) is bundled with student learning resources for every course. The credentials are free to all MBA faculty members.

Anne Reed, University at Buffalo:

Anne Reed photo - Young woman with glasses smiles at the camera.

The University at Buffalo (UB) is part of the State University of New York (SUNY) system, which released a policy framework for microcredentials back in 2018.

This framework inspired us to develop a pilot, as we saw the potential for microcredentials to help students meet their individual academic and professional goals. 

Q: What were the crucial implementation steps or processes that helped you to achieve your success?

Aurora: We are in the midst of establishing our microcredentials. It has taken collaboration, research, communication, and key partnerships outside of the institution to make the progress we have. We are hoping to launch many of our key microcredentials in the Spring of 2023.

Madison College: For us, I think it was the opportunity to try different things knowing that if they did not work, we could find a way to back out, adjust, and pivot if needed. In addition to that, it was and continues to be necessary to have someone or a group of people responsible for the oversight of the program. Once we started to have some initial success in non-credit, we were able to gradually expand into degree programming, customized employer training, and other areas of our college. As that showed more success our administration fully bought in and authorized the creation of our Digital Credentials Institute.

SNHU: Important steps include ease of access for students to the credential within the learning management software (LMS). Additionally, we related the learning within the course content to the course competencies and program outcomes. Finally, we spent time and resources teaching and encouraging students to display their badges in their social media content to promote personal branding.

Buffalo: We instated a centralized office (Office of Microcredentials) and spent almost a full year planning and developing processes before launching our first microcredentials. Developing a communication plan early on allowed us to build awareness of microcredentials and clarity around their purpose and benefits to all stakeholders. 

A centralized office has been critical to ensuring our efforts are well-coordinated, as microcredential development and implementation requires collaboration across many offices and units (e.g., academic departments, registrar). A centralized office has also allowed us to instate a faculty governance process that assures our microcredentials meet quality standards, and appropriately fit into, or complement, existing programs. 

Q: Looking back, what were your biggest hindrances to progress?

photo of a construction barrier
Photo by Tim Collins on Unsplash

Aurora: Navigating the many different layers of varying processes is not necessarily a hindrance, but an opportunity to be intentional with every step. And, it takes time to navigate those processes, which can slow progress but ultimately lead to better outcomes. 

Madison College: Probably our biggest hindrance was just acceptance that micro-credentials/digital badges were a real thing, not just a novelty, and could have real value in the market. It took some time to get faculty buy-in, but once some early adopters moved forward it has literally exploded on our campuses.

SNHU: The biggest hindrance was finding a business partner who understood our vision and could deliver a robust bundle of products to support each course in the program. We wanted one partner to work on the design that had the right textbooks, credentials, videos, podcasts, animated videos, and research that matched our vision and the learners’ needs. We spent several months meeting with different professional teams. While all the learning resource vendors had high quality products, we chose Wiley and AICPA because they were able to meet all needs. A second hindrance was designing the links within the LMS that were easy and seamless for students. We did not want students to “work” at getting to the content. The work is in learning and achieving the credentials and not maneuvering through multiple gates to access the tool.

Q: What were your “go to” resources?

Aurora: State data informing the industries of focus, workforce data, industry advisory boards, finding resources, and partnerships through organizations like The Educational Design Lab, as well as with colleagues in the respective work groups.

Madison College: There were very few organizations especially in higher ed that were utilizing digital badges when we first started (2012). In those early years, we spent a lot of time building the plane while flying…but one of the biggest influences we had would be the IBM program.

Buffalo: The SUNY microcredential policy framework has been a great resource for UB, and I encourage anyone implementing microcredentials in higher education to consider adopting the guiding principles of the framework. 

I am fortunate to have a community of like-minded practitioners across the state who also oversee microcredential programs. For me, community is a critical resource as it provides an opportunity to share practices, explore new ideas, and learn in a manner that is informal and risk-free. 

The professional organization UPCEA is an excellent resource for HED professionals who work with alternative credentials in any capacity. Over the years I have had the privilege to work with UPCEA in a variety of capacities, including as a contributor to the Hallmarks of Excellence in Credential Innovation, which is essential reading for anyone developing a microcredential strategy or managing the procedural aspects thereof. 

Q: Has your microcredential program become embedded in the fabric of your institutional operations? If so, how have you accomplished this?

Madison College: Yes, but it definitely did not happen overnight. We had to prove that these credentials were something people (earners/employers, etc.…) wanted. In addition to that, we needed a plan/policy for how they would be utilized, what the value of them would be, the graphic images, all of the pieces that make the program successful and scalable. 

Currently, one of the most integrated processes utilizing digital badges are our Articulation badges, similar to Credit for Prior Learning, which flows through our Admissions office. These badges have played a key role in helping us build and maintain community-based organization partnerships while also providing pathways into education.

SNHU: As a result of the learning and success of implementing credentials in the MBA, we were able to implement similar tools in our Accounting and Human Resources programs. These learners will now have additional tools to enhance their career potential and professional development.

Buffalo: We have been able to effectively integrate microcredentials into UB’s systems and processes. We are fortunate to have the support of university leadership, particularly our Vice Provost for Academic Affairs (VPAA), who has supported and championed microcredentials since we began this initiative. Undoubtedly, when adding a new type of credential to an institution’s portfolio, more work will ensue. This includes new procedures for administrative offices, and added responsibility for faculty who develop microcredentials and support students in earning them. This would be much more difficult, if not impossible, without trust in, and respect for, the leadership behind these efforts.

Q: What implementation advice do you have for others? 

Aurora: Allow for the time it takes to do this work well. Partner across positions within and external from the organization. Seek significant industry input, and make it an iterative process. 

Photo by charlesdeluvio on Unsplash

Madison College: 

  1. Make sure you have someone or a group of people responsible for your program. All badge creation should flow through them, at least initially to help maintain integrity.
  2. Make sure your imagery represents your organization first and foremost – you are the value!
  3. Create policy to help ensure integrity. Misrepresenting the value of one microcredential can potentially devalue all of your microcredentials.
  4. It’s easy to think about opportunities that are right in front of you, but to build a program that’s scalable, think big picture and don’t be afraid to take risks!
  5. Last but not least, many organizations I speak with tend to assume microcredentials need to be something new. I guarantee there are amazing things happening at your organization that no one knows about that you could package into a microcredential.

SNHU: One of the tenants of Total Quality Management (TQM) is developing business partnerships with outside firms who understand your own vision and mission. Your success is their success. Having one vendor to manage your “supply chain” of credentialing is both a benefit and a challenge. A benefit is having a trustworthy partnership. A challenge is getting all the needed name brand products from one source. We were able to maximize the benefit and overcome the challenges through hard work and on-going transparent communication with Wiley and AICPA.

Buffalo: Use your existing systems (e.g., SIS, LMS) and processes (e.g., curricular review) for developing and implementing microcredentials. This will improve efficiency and help internal stakeholders understand that microcredentials are a component of your institution’s portfolio, and not just a fad or inferior to other types of credentials. 

In summary, the implementation stage is where your institution can start to really impact your community, take your time to identify what is working and what can be improved as you move forward. 

We would like to thank the following individuals who generously helped with this blog:

  • Anne Reed, Director – Office of Micro-Credentials, University at Buffalo.
  • Mark F. Hobson, Ph.D., Senior Associate Dean of Business, Southern New Hampshire University.
  • Lesley Voigt, Director, Digital Credentials Institute, Madison College.
  • Jenn Dale, Dean of Online and Blended Learning, Community College of Aurora.
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Definitions of Digital and Distance Education Spotlighted by WCET this Fall

Post author By Lindsey Downs
Post date September 15, 2022

What term do you use to describe a course where technology allows faculty and students to connect over space and time? Any/all of these?

word art of the terms all mixed together

Distance learning. Online learning. Blended learning. Hybrid learning. Hyflex learning. Digital learning. Remote learning. Emergency remote learning. Flipped classrooms. Synchronous learning. Asynchronous learning. Co-modal learning. Distributed learning. Flexible learning.

Can you blame students, faculty, administrators, and the general public for being confused about all the terms we use?

One of the top three issues that the WCET Steering Committee sought to pursue in 2022 was a focus on sorting through these definitions. This year, there have been discussions on wcetMIX about how institutions are struggling with definitions that have once-again shifted in the post-COVID institutional environment…and the frustrations around that shift.

There are several works coming your way in the coming months…

The Faculty and Administrators View

What do faculty and administrators think about the definitions of common digital learning terms?

The Canadian Distance Learning Research Association (CDLRA) included some simple definitions of common terms in a survey they recently conducted. WCET engaged Nicole Johnson (who also heads the CDLRA) and Jeff Seaman (Bay View Analytics) to adapt and add to the survey for use in the United States. The first part of the survey asks about agreement of a simple definition of the following types of learning: “in-person,” “online,” “hybrid,” “hyflex,” “synchronous,” and “asynchronous.” We sought input from faculty and administrators from throughout the country using both targeted sampling and open calls to participate. For the latter, we greatly appreciated the help of the Online Learning Consortium (OLC), Quality Matters, and UPCEA in promoting their members to take the survey.

The results were published recently in the Online Learning Journal. The surprising conclusion:

Instead of confusion and contention about what these terms mean (as suggested by the literature), the findings revealed widespread agreement.

Watch for follow-up on this survey, including:

  • A free and open webcast on September 21 to present the results and engage in discussion.
  • Two WCET summaries of the findings.
  • A discussion session will be held at the WCET Annual Meeting on “Unraveling the Tangle of Digital Learning Definitions.” Shannon Riggs, Oregon State University eCampus, and Brenda Boyd, Quality Matters will engage participants in interactive sharing of what terms work or do not work in your settings…and uncover what future actions need to be taken to untie this digital knot. Join us on October 20 at 11:45 AM.
  • Discussion questions posed to the WCET community through our online platform, wcetMIX, about the results and your views of definitions.
ad for wcet webcast - Navigating the Confusing Array of Digital Learning Definitions

The Policy View

What are the policy expectations for the “distance education” definition?

In the past we have written several times about the definitions of “distance education,” which is the commonly used term by policymakers whether federal, state, accreditors, or others. Our posts included:

  • IPEDS asks institutions to follow their definitions in reporting enrollments, but we look at the different policies institutions must use to comply – October 2014 – Using a Texas institution as an example, we showed: “As shown with the ‘distance education’ definition examples, a college in Texas would need to report distance education as 51+% of a course to SACS, 86+% of a course to its Coordinating Board, and nearly 100% of a course to IPEDS. You can see the difficulties they face.”
  • Definitions and Delineations – November 2017 – IPEDS asked for insight on distance education definitions and we provided a list of variations by agency. To quote: “As you will see below…it’s a mess.”
  • Definitions in the most recent Department of Education Notice of Proposed Rulemaking – August 2022 – The Department claims: “This addition clarifies how an institution’s programs offered through distance education or correspondence courses should be considered in the context of reporting students’ locations…” We respond: “We worry it will have the opposite result without careful and comprehensive guidance.”

This fall, we will release a fresh analysis of “distance education” definitions used by federal agencies, states, accreditors, and others. We want to show that the variations in definitions that institutions face in regulations persist and that this may cause continued challenges for institutions trying to comply with requirements that vary by oversight agency.

The Student View

black and white photo taken from behind several students in graduation caps and gowns sitting in chairs
Photo by Emmanuel Offei on Unsplash

Earlier this year we conducted a focus group of students from throughout the U.S. Rather than asking them about definitions, we asked them about what they need to know about their courses before they enroll in a course.

Essentially, the definitions don’t always matter.

Students need to know what is expected of them in terms of what, where, and when they need to participate in a course.

In Conclusion…Stay Tuned

Our field of digital and distance education is shifting. We are still struggling with how best to describe what we do.

Thank you to the WCET Steering Committee Working Group members for leading on this pressing issue, including our co-chairs:

  • Brenda Boyd (Quality Matters) and
  • Shannon Riggs (Oregon State University eCampus),

and the others on the team:

  • Rob Griffiths (The Ohio State University),
  • Jory Hadsell (Foothill-De Anza Community College District),
  • Tina Parscal (CCCOnline), and
  • Kelvin Thompson (University of Central Florida).  

We hope that you will follow our work. And please participate when asked to engage in discussions about how to move forward.

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Practice

A Hopefully Interesting Introduction to Passwords

Post author By Lindsey Downs
Post date September 8, 2022
image of someone typing on a keybord with the word "password" overlaid on top of the image and a field representing a password
image of someone typing on a keybord with the word "password" overlaid on top of the image and a field representing a password

Password security is, simultaneously, one of the most important and most hated aspects of cybersecurity. To many – myself included – it’s frustrating and confounding that everyone should need so many passwords, each of which contain more complex characters, just to stay somewhat secure in our modern society. Beyond that, the fact that accounts can still be hacked, and data can still be lost, manipulated, or accessed by unauthorized parties (even when we do manage our passwords very well!) is downright infuriating.

Practicing proper password hygiene is essential to keeping ourselves, our workplaces, and others around us secure.

And yes, while many of these criticisms are legitimate, we live in the world we live in, and we have the system that we have. Practicing proper password hygiene is essential to keeping ourselves, our workplaces, and others around us secure.

In order to provide a bit more insight on the importance of strong passwords, today’s post includes an overview of secure passwords. Hopefully this approach will help make the subject more practical, interesting, and intelligible.

Authentication

Passwords are important to the process of authentication, which indicates to computers, websites, systems, etc. that you are who you say that you are. However, passwords are not the only type of information that can be used for authentication. Authentication most often requires that users provide one of the following:

  1. something you know,
  2. something you are, or,
  3. something you have.

Passwords are an example of something that you know. Knowing the password to your Twitter account allows you to log into the social media site. However, this form of authentication can be insecure, especially if you reuse passwords from one account to the next, use a password that is easy to guess, or have your passwords written down in an insecure spot. The use of PINs or security questions are other types of “something you know” beyond passwords, but they can have many of the same types of insecurities as passwords.

Graphic of a fingerprint scan

The other common forms of authentication have their own problems too. “Something you are” authentication uses biometric data. For example, many mobile devices are equipped with a fingerprint reader or facial recognition.

While the use of biometric data can feel more secure – and make you feel like you’re the star of an early 2000s spy TV show – giving corporations access to your biometric data can have its own problems. If those corporations were breached by a nefarious actor your biometric information could easily fall into the hands of hackers or even become available on the dark web (again, sounds just like a movie plot, right?).

Lastly, “something you have” refers to the use of a device (commonly called a token) that can be carried with you to give you a unique access code. For example, RSA SecurID and YubiKey are two examples of authentication tokens that can be used for secure logins. While these can be used both professionally and personally for added security, it’s not universally used. Phones can also be used as “something you have” like when you provide a phone number for an SMS text for 2-factor authentication.

2FA and MFA

Two-factor and multifactor authentication can increase security of your accounts by relying on more than one method of authentication, making it more difficult and time consuming for hackers to breach your accounts. In fact, a recent investigation showed that ransomware hackers frequently give up on hacking an account when they encounter two-factor authentication, preferring to opt for the low-hanging fruit of accounts that just use single factor authentication.

Password Storage and Security

Last spring, I took a digital forensics class, during which we spent a few weeks learning about how to crack passwords using programs, first using John the Ripper and then using Python (why anyone decided that it was okay to name a piece of software after a serial killer who murdered sex workers is baffling, but I digress).

photo of several colorful sticky notes with passwords written on them laying on a keyboard

My professor reminded us often that although we were learning how to crack passwords, and even though doing so is alarmingly easy, we should not do so unless we have expressed permission from whoever owns the password at hand, and that doing so without permission could result in fines or jail time, to say nothing of the ethical concerns. And I am passing this warning on to you ahead of getting into this description.

John the Ripper, which is one of the many tools available within the free software Kali Linux, can be used as a sort of entry level password cracking program. Which again – I’m not suggesting any of you jump right in and become a hacker – but I believe it is useful to understand that there are programs out there that can make hacking rather simple, especially for things like weak passwords that aren’t that secure in the first place.

John the Ripper, as well as more advanced password cracking tools, function in similar ways to break passwords. To get started, let’s dive into the topic of password hashes to give you an understanding of how passwords are stored. Then, I will introduce two common methods for cracking passwords – brute force attacks and dictionary attacks.

Hashes and Salts

Thankfully, not all systems or websites that have been breached will have exposed user passwords, at least not immediately. Generally, when passwords are submitted by users into websites or other systems, they are stored in hashes rather than in plaintext, which creates some level of security. Plaintext is an unencrypted way of storing information. Facebook was in hot water several years ago when it was discovered that they were storing user passwords in plaintext and leaving them accessible to employees. That means that employees could have browsed user passwords in a readable format without using any decryption tools.

Hashes on the other hand are cryptographic, computer-generated combinations of characters that represent the user inputted characters.

MD5 is one of many hashing algorithms used for encryption. It produces a 128-bit hash value from whatever string of characters is inputted.

MD5 hashing is no longer implemented very often because of known vulnerabilities with the function, but it is a useful tool for teaching, and was used in my class to help us understand the uses of hashes.

Other hashing algorithms such as SHA2 and SHA512 use much more complicated algorithms and are more often in use for password hashing in the present day.

I think an example would help here:

If I generate an MD5 hash of the word password I will see this string of characters: 5f4dcc3b5aa765d61d8327deb882cf99

If I generate an MD5 hash of the word password again, the result will be the same.

Hashing only works in a single direction, so although I can input the word password to an MD5 generator and receive 5f4dcc3b5aa765d61d8327deb882cf99 in return, I cannot input 5f4dcc3b5aa765d61d8327deb882cf99 into a program and somehow unhash the data into the word password.

A problematic part of all hashing functions is that, as mentioned earlier, any identical two passwords will always yield the same hash. Here’s an example below. Say I decide to create a long-ish password (13 characters) using a capital letter, a special character, and a number. By most website standards, this password checks all the boxes. What’s more, it’s straightforward and based on a familiar subject, so that I might just be able to remember it.

When I create an MD5 hash of Harrypotter1! I get the hash 1da62fdd9e2dc384ac0df1ae9df4459d

All good, right?

Not quite. Even though this is the first time I am ever using this password, it is based on such a popular topic that others have already come up with the same. When I enter this password into the password section of the website Have I Been Pwned, which tells users which passwords or which accounts of theirs have appeared on the dark web, I see that this password has appeared in data breaches 27 times before! The website then warns me against using this password since it has been breached.

Since the password has been breached before, hackers would have access to it and could put this password through various hashing functions so that they can compare the hashes that they are trying to crack to the hashes of known breached passwords. Once hackers determine that I use a password with that same hash, they can determine that I am using the password Harrypotter1! And may be able to breach my account – especially if they are able to access my username and I do not have two-factor authentication in place.

In addition to hashes, salts provide extra security as well. Salts are extra characters that are automatically added to passwords before they are hashed so that the result creates something unique, even if your password has been breached before. When salts are used, hackers are no longer able to find matches between the hashes of breached passwords and the hashes of still in use passwords. While the use of salts adds great security to password storage, not all organizations will practice such good password storage hygiene, and sometimes it is hard to know how your passwords are being handled by an organization until there is a breach.

Password Cracking

Now with an understanding of how passwords are stored and secured, here are a couple common ways that they are breached.

Brute Force

Brute force attacks are just about what you’d expect with a name like that. These attacks function by testing each possible combination of letters, numbers, and special characters until a match is found. In my class, because we did not have unlimited power to perform these attacks, we were assigned to just look for passwords that were up to six characters in length, so when we tested our scripts, we used passwords at or below that maximum.

Photo of someone typing on a laptop with graphic of a lock overlaid on the photo.

While these tests that we did in class often took less than a minute, cracking passwords by brute force can become very time and energy consuming very quickly when the number of characters involved increases, which is one of the benefits of using long passwords.

Brute force hacks are impractical when used on live sites that have login attempt limits. Although that feature can be frustrating on sites that use it, especially if your account is locked for a short period of time after you failed to enter the correct password too many times, it is also quite useful. However, websites without such a feature remain vulnerable.

Hashed passwords leaked in a data breach are also vulnerable to being cracked as hackers can perform their attacks offline and then can use hacked passwords to get into live accounts when passwords are not changed after a breach.

Dictionary

A dictionary attack functions by comparing the hashes of known words, phrases, and previously hacked passwords to the hashes of passwords that they are trying to breach. In fact, there are downloadable wordlists available online that list millions of previously breached passwords, which computers can quickly hash and then compare to the hashes of passwords they are trying to hack. One shocking example can be seen in the wordlist available on GitHub called rockyou.txt. This wordlist comes from a massive 2009 breach of the website RockYou and contains millions of unique breached passwords.

Beyond just the use of wordlists, John the Ripper also allows hackers to use “mangling rules” which allow them to use their computers to quickly check the words on their wordlists as well as the same words with common substitutions. For example, many people substitute the “@” symbol for the lowercase “a” as a way to add a symbol to their password without the result being too difficult to remember. Similarly, some people might use a “0” in place of an “o” to achieve a similar effect. However, if a hacker is able to use mangling rules to search for this type of variation, a password like H@rryp0tter becomes less secure than it may look at first glance, even though it meets all the usual password requirements.

Organizational Responsibility, Your Responsibility

It’s pretty clear after reviewing password storage methods that organizations have it within their means to provide high-level password security to their users if they choose to by using hashes and salts and requiring 2FA or MFA. However, organizations may also practice poor password hygiene. Some organizations may not have the funds nor manpower to be as secure as they could be, while others may choose not to put the resources that they have available into security, to the detriment of their users. As users, we may occasionally have the option and forethought to only have accounts with secure organizations. Often however, I feel like many of the online accounts that I make I have no other option for and simply hope that the organizations are practicing good security. Therefore, it is always in my best interest to practice very good password hygiene for myself, especially because it is the users who often must pay – at least metaphorically – when our data is breached.

As a non-IT employee, it may not be my responsibility to implement the systems that create security. However, I still have responsibilities as a non-technical employee. By securing my own work accounts, I can help to ensure that our organizational systems are not penetrated by hackers.

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Practice

Back to School means back to campus for nearly all…but is it where they want and need to be?

Post author By Lindsey Downs
Post date August 30, 2022
example of the charts in the blog post

It’s Back to School time and while the season is filled with its typical excitement for new beginnings, this year there are certainly additional considerations when it comes to heading back to campus.

Today we welcome back Kara Monroe, who continues her excellent list of guest appearances with a focus on returning to campus and remote work. Does your campus have a remote work policy? What do your staff and faculty truly want when it comes to these policies?

Enjoy the read,

Lindsey Downs, WCET

I am intrigued by the ways in which organizations of all types are responding to the forced work from home experiment nearly all of us had to do as a result of COVID. And, more importantly, how organizations are now bringing their workforce back into the office.

In late summer, I polled my network to find out how their campuses were handling the question of remote work and what their personal experiences were with remote work before, during, and now in whatever this post-COVID world is.

The sample size for the survey is only 30 individuals so it is certainly not something that allows us to draw conclusions. However, data points like this can offer great opportunities for further study in our own environments.

Who completed the survey

While the sample size was 30, it was a fairly diverse sample. Here are a few key characteristics of the survey respondents:

  • 63% are from public 2 year institutions and 30% are from public 4 year institutions.
  • Respondents live in 7 states, with the majority being Indiana residents (my home state, so where my network is densely concentrated).
A chart with responses to whether organizations had a remote work policy prior to March 15, 2020, showing that 27% said yes, 57% said no.
  • Only 32% of respondents work at an institution that had a remote work policy before COVID – whether developed, being developed, or being piloted. 86% of institutions now have a policy being piloted, being developed, or developed.
A chart showing responses to whether organization has a remote work policy now, showing 69% said yes, 10% said no.

Governance and Remote Work

One of the most surprising data points in the survey is the overall lack of employee involvement in the development and approval of remote work policies. Remote work policies appear to be largely a privilege of leadership with little approvals from employee governance groups.

A graph about responses to the level of approval required to work remotely, showing senior admin/president is required 50% of the time.

In addition to the basic data point, many comments call out that the ability to access and use remote work is largely left up to individual supervisors. One person said, “My institution has a Remote Work policy, but our academic college is not permitted to use it/take advantage of it, as our Dean will not approve any remote work.” Comments also alluded to the stick versus carrot approach being taken in some organizations regarding new remote work policies, “My institution put together a great telework policy but the Senior Leadership started implementing rules that were not required of the policy, placing barriers and limitations that made it hard to access telework. The new campus President and Interim President both sent threatening messages at different times about their ability to take this “privilege” away when employees were concerned about the policy not being applied equitably across campus.”

Supporting Remote Work

My nephew works for a private company in New York City – which obviously has private company resources. They routinely had lunch provided at the office. When COVID hit, they received regular gift cards to replace this in office benefit at home.

The story in higher education is very different. While most employees can access a laptop if they need one for remote work, that is where the benefits end. Mobile phones and access to VoIP phones, Internet access, and office furniture are rarely provided by higher education remote work policies. One person even indicated that they were not permitted to take office supplies home from the office to do work from home. If they worked from home they were told the expectation was that they would provide everything they needed. While I realize that a sample size of one is not valid for any statistical sample, it’s important to consider the underlying attitude here and what it says to the employee about how you are treating them and the importance of the work they are doing – regardless of the location where it is done.

Even with the lack of work-related benefits, employees still see many financial and personal benefits to working from home. Many people mentioned both savings on fuel costs and commuting time (not to mention potential decreased COVID risk….). These represent two of our most precious resources – time and money – and so they may very likely overwhelm any other perceived missed benefits.

What People Want

The final part of the survey examined people’s beliefs and perceptions about their experiences working from home and what they want now.

The majority of people who responded to the survey had never been a part of a formal work at home arrangement prior to COVID and only 34.5% had worked from home/an alternative location prior to COVID.

graph with results about format work remote agreements being in place at institution. 80% indicated no.

More people now prefer solely remote work post COVID (10.3% pre-COVID to 20.7% now). An important question for study is what will happen if these folks decide to leave higher education institutions that won’t allow this and seek other employment that does since the entire world of employment opportunities is open to them as a remote worker.

The bigger issue which I think the survey points to is the professionalism attributed to employees and their ability to choose work location based on activities on their calendar that day. The percentage of employees who prefer a schedule that allows them to choose their work location from day to day did not change – it was 27.6% pre-COVID and is 27.6% after COVID. This is despite the fact that 75% of individuals who took the survey indicated that they were promoted in the period from March 2020 to now and the vast majority of individuals have less than 50% of their time spent in direct student engagement.

Notice the disparity in the two graphs showing perception of how much work must be done on campus versus how much employees are required to be on campus.

Chart showing percentage respondent's job "must be completed' on campus/work location. Highest number was around 10-25%.
Chart indicating respondent percentage of job required to be completed on campus/assigned work location, with a majority responding between 80-100%

What does this mean for organizations and for leaders?

One of the biggest challenges plaguing many organizations today is attracting and retaining qualified talent. This comment summed up what many offices have experienced over the last year, “I have an office of 10 positions. 4 people have resigned in the past year, three for fully remote positions that require less responsibility and pay more money.”

Higher education organizations did a massive experiment duringCOVID19 but how have they used the results of that experiment to make their workforce happier? Again, the sample size is small but this survey provides many questions I think leaders need to think about as they try to attract and retain talent in a hectic workforce.

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Policy Practice

Coming Attractions: Can’t Miss Features from WCET this Fall

Post author By Lindsey Downs
Post date August 25, 2022

The one constant in life is change. The variable is the pace of change. And lately, it seems change has accelerated.

movie theater seats and curtain
Image by Andreas Glöckner from Pixabay

The academic year has either just started, or you are preparing for it to start shortly. And while fall normally is a season of change, we are hearing about more drastic changes from our members this season, including enrollment levels, enrollment patterns across modalities, changes in modalities offered, and worries about quality education in today’s educational environment.

This post focuses on coming works that address the changes in the air. With all you are doing, you are probably too busy to read this post. BUT WAIT…don’t go away. We hope you persist as we preview the fall for WCET and let you know about an exciting new collaboration!

Coming Attractions

Most of you know of my affection for movies and I’ll be sad to miss the Telluride Film Festival this Labor Day. I do enjoy “coming attractions.” It’s fun to see the snippets of films coming to a theater (or streaming service) near you.

Although, this might not be quite as entertaining as the teaser trailers you’re used to…here is our version of what is coming your way from WCET…

WCET Annual Meeting, Part 34

“In a world”…in which Zoom sessions linger ominously around every corner, the WCET Annual Meeting, forges a new path to engage pioneers on the lonely and dangerous frontier of digital learning.

Ok. Maybe it’s not very dangerous…but this year’s Meeting will be worth your time. This year, we are reimagining in-person meetings. We are changing what we do. We might not have it right yet, but you will see changes and we hope you will help us shape what is needed for the future. We will be inviting some of you to focus groups to help us do just that by discussing WCET services and wcetMIX.

As for what will happen this year, we are trying ways to have more engagement and sharing within sessions. Come experience it with us!

Microcredentials

It’s rare to see a short film anymore, but they are often very rich experiences and are tailored to the length of the story. Similarly, I believe we are seeing a shift in student demand leaning towards credentials that are shorter and fit better fit with student needs.

The WCET Steering Committee Working Group on microcredentials started their WCET Frontiers blog post series last spring. So far they have reviewed the importance of understanding the strategic goals of microcredential projects and the value that clarity of terms plays. Those covered the “why” and “what.” Last week’s post focused on the “how” with insights on starting from the beginning.

Continuing this saga, in the coming weeks, watch for additional posts addressing implementation, and evaluation.

Work on Digital Learning Definitions

You, our members, have let us know that the way faculty use digital learning has changed. This has often resulted in less agreement on the definitions related to digital learning…or created new ones. Arrrgh! Earlier this year, the WCET Working Group on Digital Learning Definitions asked you to take a survey on your agreement with short definitions of course delivery options, such as online, hybrid, hyflex, and in-person courses.

On September 21, WCET will host a free webcast to announce the surprising results and stay tuned for short publications that address several questions about the definitions.

From the policy point of view, also watch for analysis on the many definitions that institutions are expected to use in complying with the rules of different government, accrediting, or other organizations. What hasn’t changed…they still don’t agree.

And we want to hear from students. Spoiler alert…they don’t care what you call it. They just want to know UP FRONT what is expected of them. We’re the ones who must change to meet that need.

Equity and Quality

Not to be outdone by their Steering Committee colleagues, the Equity and Quality Working Group will have a series of posts in October and November. As we expand the use of digital learning, we need to ensure that all populations not only have access (which many don’t), but can actually succeed. The notions of “quality” some into play.

The posts will focus on faculty and student views, tools for ensuring quality, and sharing advice and lessons learned.

SAN Workshop on Compliance Continuity

There is still time to register for the State Authorization Network’s virtual workshop on “Succession Planning for Compliance Continuity.” Like making a movie, those responsible for compliance work best with a well written script, continuity, and clear direction. You can learn much from this workshop, which will be held September 7th -9th.

An Exciting New Collaboration

Do you enjoy reboots of classic movies? We enjoy some of them, and we are very excited about this one.

The new Annual Summit for Women in eLearning (ASWE) is the reboot of the International Forum for Women in E-learning (IFWE) previously hosted by USDLA. We are very committed to advancing women in digital learning. The ASWE community is focused on connecting, learning, and supporting others in the field of digital learning—

  • As we lead.
  • As we learn.
  • As we lean.
  • As we live.

ASWE will rotate between an open house gathering and reception on even years and the day-and-a-half Summit in odd years, both in conjunction with WCET’s in-person Annual Meeting. This year is the open house event and a book club discussion. Come join the fun.

Have a Great Year!

WCET staff just had their annual retreat this week. I am reminded what a fantastic staff is here to serve you through WCET membership services, the State Authorization Network, and Every Learner Everywhere. They really are remarkable.

We wish you happy endings for you and your students.

Russ

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Practice

Starting at the Beginning – The inception phase of microcredential efforts

Post author By Lindsey Downs
Post date August 18, 2022

Welcome to the continuation of the WCET + WCET Steering work group series focused on microcredential initiatives. This series explores microcredential adoption, implementation, and evaluation. Previously, the series has reviewed the importance of understanding the strategic goals of microcredential projects and the value that clarity of terms plays in an emergent area.

With today’s post, from Gary Chinn. WCET Steering Committee member and, Assistant Dean, Digital Learning, The Pennsylvania State University, we will move from necessary conversations regarding the “why” and “what” of microcredentials, and begin to consider the aspects of “how.”

Thank you to Gary and the entire working group for this outstanding series!

Enjoy the read,

Lindsey Downs, WCET

Project Inception – The Key to Shared Vision and Effective Execution

Inception is a key phase of the project lifecycle that moves strategies and ideas toward something more tangible. With the primary goal of stakeholder agreement on overall objectives, the inception phase aspires to determine elements of project scope, necessary resources, inherent risks, and overall feasibility. Alignment with the “why” is of critical importance in the inception phase, since institutional motivations and objectives will shape many of the decisions related to team formation and a shared vision of success.

As the Non-Profit Research Institute (RTI) describes, the inception phase can be useful for clarifying the context for project implementation. Inception often involves pilots (or “small bets”) which can provide key information to inform adaptation in objectives as well as reveal gaps in the project team by illuminating stakeholders who might not yet be included in planning.

Helpful outcomes from an inception phase include:

  • A shared vision for the benefits to be gained from microcredential efforts,
  • Establishing what success will look like, based upon the shared vision,
  • Determining project leadership and community stakeholders necessary for effective execution.

To illustrate these important aspects of project inception, we drew upon the expertise of two talented and engaged members of the WCET community to share their perspectives:

  • Sherri Braxton, senior director for digital innovation at Bowdoin College who previously led badging programs at the University of Maryland, Baltimore County (UMBC); and
  • Jessica DuPont, executive director of market development and the student experience at Oregon State University Ecampus.
Image gallery image
Sherri Braxton
Image gallery image
Jessica DuPont

Please note, the interview answers below have been lightly edited for length and clarity.

Creating Shared Vision Through Aligned Institutional Objectives

Braxton (UMBC):

Some of the expected benefits from the UMBC badging initiative were:

  • Building a badging infrastructure tied into LinkedIn, UMBC, so the institution could follow student progress after graduation. Specifically, UMBC wanted the ability to identify learning experiences that made a difference in future career success.
  • Determining student participation levels in extracurricular activities to understand the impact such activities have on graduation rate, time-to-degree, and post-graduation success.
  • Providing a guide for students on co-curricular skills that will highlight building their career skills or on positioning themselves to succeed in graduate school.
  • Identifying interests and expertise that can be pulled into a variety of interdisciplinary research projects.
  • Supporting skill acquisition amongst staff (e.g., project management, leadership, business skills, analytical skills, organization skills).

DuPont (Oregon State):

Oregon State University launched its first microcredentials in the fall of 2021, with initial offerings available in winter quarter 2022. All Oregon State microcredentials are for credit and consist of at least three courses and eight credits that follow Oregon State’s quarterly term calendar. See this page for a current listing of available microcredentials, all offered online.

Our centralized online learning division (Ecampus) spearheaded this initiative with our Associate Provost at the helm. One of the first steps involved seeking internal buy-in, meaning communicating the benefits and trends of alternative credentials to internal OSU

stakeholders. Namely, we highlighted that not all learners seek a full degree or a traditional credential. Leadership in our division had been closely following the rise of alternative credentials, numerous market insights, as well the demand in the marketplace to more nimbly upskill and reskill America’s workforce. Communicating this opportunity was key and while all internal OSU partners were highly supportive, it was somewhat challenging for a four-year public institution who has offered traditional credentials for more than 150 years.

Defining Goals & Learners

Braxton (UMBC):

UMBC is implementing badges on two fronts: badges specific to UMBC, which are offered to their students, faculty and staff, and badges defined through collaborations with external partners like the University System of Maryland and the Greater Washington Partnership, coalition of employers and higher education institutions.

UMBC adopted digital badging as a mechanism for capturing the achievement of competencies within the numerous activities taking place at the institution in a way that would allow badge earners to not only reflect on these newly acquired skills but also to share their achievements with others, including potential employers.

In 2015, just as UMBC was embarking into the digital badging space, the University System of Maryland (USM) Kirwan Center for Academic Innovation was also exploring digital credentialing. The purpose of the Kirwan Center is to support inter-institutional collaboration across the USM institutions and promote academic innovation that results in new opportunities to improve student success and to scale effective practices in a sustainable way. The Kirwan Center was looking for ways to address an issue reported by graduates from the USM institutions: many students were not able to articulate the career-ready skills they had acquired during their time at the institutions.

Example digital badges with school related icons
Example digital badges

The solution to this issue came in the form of an initiative known as B.E.S.T. – Badging Essential Skills for Transitions. Through the implementation of eight digital badges focusing on essential career-ready skills identified by the National Association of Colleges and Employers, including collaboration, communication, critical thinking, globalism, interculturalism, leadership, problem solving, and professionalism, nine of the 12 USM schools collaborated to define the frameworks, or dimensions, for these badges, acceptable assessment strategies, and agreed-upon rubrics derived from the Association of American Colleges & Universities’ Value Rubrics on which those assessments would be based.

More recently, UMBC has been working with the Greater Washington Partnership to bridge the gap between higher education and the workforce and provide access to exclusive professional development opportunities to attract and retain talent. In collaboration with regional employers, the CoLAB created the Digital Generalist Credential that captures six core competencies to educate non-STEM majors in the areas of Data Security, Data Ethics, Data Visualization, Data Manipulation, Statistics, and Data and Analytics.

The Digital Generalist Credential modules were developed within the edX learning management system by Instructional Technology staff at UMBC with faculty from the relevant disciplines acting as subject matter experts (SMEs). The courses are designed to be self-paced learning experiences for non-Science, Technology, Engineering and Math (STEM) learners looking to pursue employment within the Greater Washington region. Current students may opt in at any time to complete these modules during their college career. Learners may choose to do one, two, or all competencies to not only gain new knowledge in the areas of STEM, but to be eligible to earn stackable digital badges along the way.

Bringing the Right People Together

DuPont (Oregon State):

In addition to Ecampus leadership, others involved in early discussions included the Office of the Registrar, the Vice Provost for Academic Affairs, the Vice Provost for Enrollment Management, Dean of Graduate School and the Provost. Ultimately, the Office of the Registrar led many of the logistics of this initiative; however, it was deemed early on that Oregon State would launch microcredentials as a pilot using only online courses. Ecampus helped to move this initiative forward by conducting faculty outreach, marketing and communications of microcredentials, and thinking through the student experience. The Office of the Registrar finalized our agreement with Credly for badging, formed and led the faculty review committee, and now tracks completion of microcredentials within our Student Information System.

A faculty committee was formed during the early phases of the initiative. They helped to further define microcredentials for Oregon State and created a modified curricular approval process that was simpler than the curricular process for full degree programs.

Determining Institutional “Ownership” of Projects

Braxton (UMBC):

The CIO was the campus champion of the badging program (and provided funding for all resources); I was the institutional owner when it came to implementation; instructional technology staff supported the initial efforts.

DuPont (Oregon State):

photo of people in a work meeting, two are shaking hands over the table.
Photo by fauxels on Pexels.com

The institutional owner for microcredentials is our University. As mentioned previously, microcredentials were initially launched as an Ecampus/online offering and many implementation details were led by our division of Ecampus. The Office of the Registrar had a project manager for this initiative, especially around microcredential coding and SIS/Banner integration. Faculty Senate Executive Committee charged the faculty committee approving microcredentials quarterly and invited participants; the Office of the Registrar led those meetings (and continues to do so). Outside of a nominal badging contract agreement, most of our project resources have been staff resources and some marketing expenses. Internally at Ecampus, we also formed a microcredentials work group comprised of Ecampus’ Associate Provost, Executive Director of Academic Programs and Learning Innovation; Executive Director of Market Development and the Student Experience; and Director of Marketing and Enrollment Services. We meet bi-weekly to stay on top of the many moving parts entailed in this initiative, including enrollment reporting, approvals, coordination with university stakeholders, etc.

The Value of Pilots

DuPont (Oregon State):

Our initial strategy, a two-year pilot (AY2022-2024), has been fairly low-risk and low-cost in terms of course development. It entailed clustering existing online for-credit courses that were part of existing Oregon State University online degree programs offered through OSU Ecampus into subject areas that either showed higher demand in industry or the consumer market or that showed higher enrollment in online courses/subjects. We did not build new courses for the pilot at launch. Initially our microcredential courses designated for this pilot are only delivered online. Options to offer and promote on-campus microcredentials will be considered after the two-year pilot. Many initial microcredentials included course work that was required for a credit-bearing undergraduate or graduate certificate or full degree programs offered online. Our early thinking and design included an intentional stackability option for microcredentials to count toward other credit-bearing credentials.

Monitoring Progress

DuPont (Oregon State):

Some of the early indicators of progress included the following:

  • Enrollment in initial microcredential offerings during inaugural term.
  • Faculty from a variety of colleges and disciplines have expressed interest in proposing these short-form offerings, which is possible through an online form.
  • A recent statewide consumer survey conducted by our division showed prospective student interest in the concept of microcredentials, though low awareness for that term.
  • OSU corporate collaborators offering tuition benefits to their employees have expressed interest in microcredentials to upskill and reskill their employees.

What Have You Learned from Your Microcredentials Experiences?

Braxton (UMBC):

The beginning of any innovative program on campus must be pursued carefully and deliberately. Understanding the campus culture and building collaborative relationships and buy-in from key stakeholders are critical factors that will ultimately determine the success of the initiative. It is important to starting small with pilots to create space to experiment and learn what works and what needs modification. We are in the very early years of microcredentialing. Ensuring that the campus community understands that it is still early and that programs may evolve as time passes and lessons are learned, is also important.

Comment bubble artistic drawing
Image by Manuel Schäfer from Pixabay

Innovation requires flexibility in approach and the time and space to experiment, fail, and apply lessons learned to the next iteration. Also, leveraging tools currently available may not be ideal to achieve all the identified goals, but are “good enough” to test some ideas and approaches while better tools are in development. Finally, a solid, skilled team is necessary to tackle these challenges, and it is imperative that team leadership has a firm grasp of effective collaboration, strategic thinking, and change management skills and approaches to work in these areas.

DuPont (Oregon State):

  • A better understanding of the audience for microcredentials will be essential for successful recruitment and future enrollment. For example, are microcredentials primarily for current students in your degree programs? New students only interested in a microcredential? Students interested in stacking a microcredentials into a degree at some point? These audiences all have different needs and entail different recruitment tactics and support services.
  • Thinking through and designing an optimal student experience, especially for brand new students starting at your institution with microcredentials. You’ll need to consider what does student support look like? Often, advising isn’t accessible for non-degree students pursuing courses. How will they feel a sense of belonging or connection to your university?
  • There is low consumer awareness for microcredentials. Building awareness for this type of alternative credential and its benefits needs to happen in tandem with recruitment efforts.
  • Leveraging established marketing tactics and budget. Marketing individual microcredentials is almost like marketing individual courses, which is not scalable. Better understanding how to leverage marketing/promotion with current efforts to market your online offerings will be more efficient and scalable.
  • Is what you’re offering in-demand? Consider collaborating with corporate entities or professional organizations to develop and offer microcredentials that will help upskill and reskill their workforce. Employer recognition and endorsement of microcredentials will also help to boost awareness and recognition of microcredentials.

Thank you again to Sherri and Jessica for sharing your experiences for this post!

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Event

WCET 34th Annual Meeting: Together again with so much to celebrate!

Post author By Lindsey Downs
Post date August 11, 2022
illustrated mountains with the night sky and "denver" written across

In November 2019, the WCET community of higher education digital learning leaders and practitioners met in Denver for one of our largest and most successful Annual Meetings. At the end of the event, we were excited to see everyone the following year for our first Annual Meeting in Indiana in fall 2020. Little did we know that we’d instead be planning a fully virtual event.

Flash forward to two very long years later, we are eager to be together in Denver once again. We planned for a smaller, more intimate event as we know networking and connecting with people is something we are all craving. We have missed you! We’ve also missed interactive sessions, endless cups of strong coffee, hallway conversations, and more, which I highlight below.

What We’ve Planned for 2022: A Timely, Interactive, and Distinctive Program

Our main goal for each year’s WCET Annual Meeting program is to showcase the incredible people in our field who join us to share their expertise, lessons learned, and good practices in advancing digital learning. This year is no exception, the conference program is a unique blend of unconference sessions, workshops, loosely organized conversations, and more. All sessions will be interactive and include key take-a-ways. This year’s topics include:

  • Microcredentials.
  • Equitable access for digital learners.
  • Strategic planning and change management.
  • Academic integrity.
  • Rubrics for evaluating technology and accessibility.
  • Student-centered learning.
  • OPMs (the good, the bad, and the caveats).
  • Cultivating community across the institution and despite the modality.
View the Full
Program

2022 General Sessions

This year’s general sessions feature inspiring speakers that are truly impacting learners. Our closing keynote is Dr. Mordecai Brownlee, who will share about Utilizing Technology to Create Mission-Driven and Equity-Centered Academic Pathways and his journey as a Community College President in a rapidly evolving landscape.

Policy sessions

WCET is known for bringing regulatory and policy updates to the community and translating key policy issues. We highlight what you need to know and how each issue will impact your day-today, so you don’t have to! This year’s policy related sessions include topics like:

  • Regular and Substantive Interaction.
  • Compliance Management for Out-of-State Activities.
  • Emerging Challenges in Distance and Digital Education Accreditation.
  • What’s next with Negotiated Rulemaking.
  • Professional Licensure.

2022 Speakers

Beyond the topics, it’s the people. We have an all-star roster of speakers and can’t wait for you to connect with them. Here are a few of the speakers for this year, but there are many more – check out the 2022 Speakers page.

Collage of photos of 2022 speakers. full list of speakers can be found on the conference website. https://bit.ly/wcet2022speakers

Exciting Additions to the Program

WCET + ASWE

Announced earlier this week, USDLA has handed the IFWE torch off to WCET. IFWE was the International Forum for Women in E-Learning and has been rebranded as ASWE, the Annual Summit for Women in eLearning. The 2022 WCET Annual Meeting will include an open house reception and book club for ASWE alumni and those interested in participating in future ASWE events. In odd years, the full ASWE summit will occur in conjunction with the WCET Annual Meeting. The first WCET + ASWE event will take place in New Orleans, Louisiana in October 2023.

2022 WCET Awards

The pomp and circumstances of awards is not quite the same on a virtual platform so we are ecstatic that we will be back in person to applaud and stand collectively to recognize our esteemed awardees during lunch on October 20. Another benefit of being on our home turf is that those named for two of our highest honors, the Dick Jonsen and Mollie McGill award and the Sally M. Johnstone awards will be present to bestow honors on the awardees who will be announced in-person.

The WCET Outstanding Work (WOW) Awards honor institutions or individuals who are advancing learner access and success through postsecondary digital learning for a more equitable world. Awardees will be highlighted in the WCET Frontiers Blog, Frontiers Podcast, and invited to attend the WCET Annual Meeting at a significantly discounted rate.

The Dick Jonsen & Mollie McGill Award is given each year to an individual who has made a significant contribution to the digital learning community and WCET during his or her career.

The Sally M. Johnstone Award recognizes a professional who has made an outsized contribution for their ‘rank’ to the digital teaching and learning community with the intention of recognizing thought leadership, excellence in practice, and demonstrated leadership capabilities.

The SANsational Award recognizes outstanding efforts by SAN member institutions and organizations in developing a high-quality, comprehensive solution to a challenging state authorization issue.

Networking Events

Register before the early bird
rate expires on August 24

We know that connection is vital and that we have all been craving the opportunity to chat with our peers and build our networks in a face-to-face environment. Zoom has been an incredible asset over the past few years, but the WCET Annual Meeting is exclusively in-person because we know attendees aren’t traveling to view a screen, more so now than ever, they want to connect and share their stories. We have built in numerous opportunities for meeting and greeting including a welcome reception, group dinners, young professionals meet-up, and our popular 5K run/walk.  

Heading Back to Denver

See You In…

How fitting that we are back at the Mile High City, after a two-year break from in-person conferences? Our host hotel, the Denver Downtown Hilton, is located near fantastic restaurants, shopping, and culture. Hockey fan? We’ll be planning a group outing to watch the 2022 Stanley Cup winners, the Colorado Avalanche, play on their home ice. And Denver International Airport has made numerous improvements to increase efficiencies and traveler experience. We hope you are excited to come back to Denver too!

I could go on and on about all the reasons I’m thrilled to be back in-person for our 34th Annual Meeting, but the most important reason for me, is the people. The WCET Community is the most generous, smart, and dedicated group of digital learning postsecondary education professionals around. I constantly learn from our members and the WCET community and look forward to learning more about you and the work you are doing for students when we connect in Denver, October 19-21. Book your hotel room while rooms remain and make sure to register before the early-bird rate expires on August 24. See you soon friends! It’s been way too long!

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Practice

Lessons Learned from Listening to Learners: an online program’s early days

Post author By Lindsey Downs
Post date August 4, 2022

Whenever we hear of intriguingly innovative programs happening in the digital learning space, we hasten to share the details with you. That’s why we’re excited to help showcase a new online program focused in on the lifelong learning space that we found exciting!

In today’s post, ReadyTrack, a pilot program run in association with Western Governors University, shares some lessons learned from working with adult learners in the continuing education space.

Enjoy the read,

Lindsey Downs, WCET

Addressing The Complexity of Learning

Creating a new course offers sobering reminders of the complexity of learning. It is the ever-invigorating quest of the educator to spark intrinsic motivation and identify the dose of struggle that generates productive friction without discouraging the learner. Fostering that experience for an individual learner is already a daunting challenge—scaling that experience can be downright flummoxing.

“It is the ever-invigorating quest of the educator to spark intrinsic motivation and identify the dose of struggle that generates productive friction without discouraging the learner.“

Juggling those demands has been my daily challenge this past year as the Head of Learning for ReadyTrack, a pilot program run in association with Western Governors University. ReadyTrack is still in its nascent launch stage, but the team has already experienced several victories and taken its lumps. In the spirit of reframing lumps as learnings, below we share three lessons learned from our first year, lessons which have boosted student participant retention rates from 40% to 56%.

But first, what is ReadyTrack?

ReadyTrack’s mission is to equip aspiring talent—focusing on women and people of color making under $35,000 annually—with the skills and relationships needed to launch front-end and back-end engineering careers. ReadyTrack assumes no prior technical training beyond basic familiarity with a computer and relative comfort navigating a web-based experience, and the program is currently provided at no cost to learners, whose tuition is covered via sponsors, grants, government assistance, and other collaborations with community-based organizations.

Readytrack yellow logo over a photo of two people working on a computer

The model entails partnering with workforce boards and community-based organizations who identify program candidates and support them holistically during the learning experience. ReadyTrack learners, also known as Track Stars, who complete the training portion of the program seek out paid work-based learning experiences with ReadyTrack partners, typically in the form of mentor-guided apprenticeships. The entire experience is designed to last 13 months, with 30 weeks of technical training followed by six months of apprenticeship. In that time, ReadyTrack seeks to connect Track Stars with the resources they need to learn confidently and progress toward their goals.

The Training Experience

ReadyTrack courses consist of a combination of live online sessions and asynchronous work hosted in D2L’s Brightspace LMS. The sessions are guided by Practitioner Mentors (PMs), who are subject matter experts that monitor learner progress and assist Track Stars as needed. In addition to encouraging collaborative work and providing just-in-time support during the live sessions, PMs hold office hours and make themselves available for 1-on-1 time. There are also weekly sessions dedicated to cultivating “soft skills”—which we refer to as Power Skills—led by ReadyTrack’s Career Coach and Strategist.

A laptop sitting on a desk showing a screen from the readytrack program.

Progression through coursework is bounded asynchronous—Track Stars do not have to progress in lockstep on a day-to-day or even week-to-week basis. Instead, they complete tasks within each of the three 10-week courses, and they must complete at least 80% of assigned coursework to progress to the next one. Along the way, Track Stars that fall one-to-two weeks behind receive personalized outreach to discover if they are stuck, discouraged, or putting out fires in other areas of their life. The outreach includes targeted interventions. Some key projects have deadlines that are common to all learners to facilitate group efforts and to create opportunities for peer review and feedback. The flexibility of the Brightspace LMS allows us to capture these various use-cases.

Track Stars Hit the Finish Line

Our first pilot cohort saw 40% of onboarded learners complete the 30-week training program. The second pilot cohort benefited from adjustments that ReadyTrack made based on the first cohort, such that 56% completed the training portion. ReadyTrack recently enrolled its first non-pilot, fully externally sponsored cohort, and has 66% retention with four weeks left.

A graph showing the "building blocks" of readytrack. Technical skills - front end focus with a broad introduction to a backend Power skills - Soft skills required by employers to contribute to a productive work environment. Peer-Peer - Weekly live learning team sessions with fellow learners and a practitioner mentor. Career Prep - Services to assist learners with resume writing, interview skills, employer matching.

Three Early Lessons

The first two pilot cohorts of Track Stars have already revealed some interesting challenges and tensions. We believe that such tensions point to potentially transformative opportunities for any educational provider working with adult learners.

1 – The tension between asynchronous learning and cohort dynamics is challenging—but it has thankfully pushed us toward the power of peer learning.

The typical Track Star has a lot on their plate. They juggle work, childcare, and other community responsibilities. Studying full-time isn’t an option and nailing down a regular daily study schedule isn’t a given. ReadyTrack’s training experience accounts for this by heavily weighing work that can be done asynchronously.

On the flip side, cohort structures provide significant benefits that can supercharge learning, including social capital building and opportunities to simulate workplace team dynamics. Harnessing those benefits requires Track Stars to not be too spread out in the material relative to each other. Unfortunately, Track Stars have consistently drifted far apart within each 10-week course, making group projects slated for the back end of the courses difficult to execute.

While we are bolstering mentorship and establishing more frequent checkpoints to reduce that spread, we are finding that helping Track Stars teach each other is key. Peer learning converts individual learning into individual mastery plus collective learning. Helping learners actively invest in the cohort’s collective progress is transforming our pacing tension from a bug to a program feature.

2 – A pocket of learners wants more rigidity in course structure and grading—we believe that what they really want is more compelling assignments.

While several learners have expressed appreciation for a more flexible experience, both in scheduling and in favoring formative knowledge checks and ungraded coding projects, a handful of Track Stars say that they prefer more regimented live sessions with lectures and stricter grading. One Track Star surprised himself in expressing this preference, given that he disliked that aspect of his K-12 experience. They also cited a concern that the lack of grades made the program feel less legitimate and motivating.

It is still unclear why some learners prefer a more traditional structure. It may partially be a matter of gravitating towards the familiar. But more likely, ReadyTrack needs more of its assignments to honor learner autonomy—helping learners apply their new skills to what they most care about—and to clearly demonstrate to them their growing competence. In other words, learners’ desires for extrinsic motivators can reflect that a program is insufficiently nourishing intrinsic motivation, and/or that the program needs to better help learners see their own growth.

3 – Learners have most consistently voiced appreciation for the “soft skills” portion of the program—so it’s time to double down.

Beyond the technical training, ReadyTrack holds sessions to encourage a success-oriented mindset via the development of Power Skills. We cover topics such as building self-confidence, identifying and leading with strengths, learning how to tell your story, and even learning how to ask for help. One topic that particularly drives interest is recognizing Impostor Syndrome. Many Track Stars begin pinpointing feelings of inadequacy as an obstacle to their learning or for their transition into the tech workforce.

Learners consistently gush about how helpful and affirming these sessions have been. We suspect that incorporating explicit Power Skills lessons starting with the second pilot cohort accounts for a considerable portion of ReadyTrack’s improved retention numbers. Beyond learners being hungry for these skills, employers demand and appreciate them. Education and training providers of all stripes should consider explicitly covering Power Skills, regardless of discipline.

As ReadyTrack has pressed forward, the above learnings have coalesced into a hypothesis that taking traditional course offerings and simply layering on …wraparound supports is inadequate. That approach presupposes that traditional learning environments and practices in the tech space have been inclusive on all axes minus socioeconomic status, which we already know to be dubious given the lack of diversity that continues to plague the tech industry.

Incorporating our Track Stars’ voices and embracing the fullness of their complex learning needs will thus be at the frontier of our course building. ReadyTrack is eager to work with our Track Stars to create the expansive and rigorous learning environment they need to launch their careers.

About D2L

Personalize learning, increase engagement, and help learners achieve more than they imagined possible. D2L Brightspace offers flexible and robust learning solutions for every stage of life, from the earliest days of school to higher education and the working world.

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Policy

Notice of Proposed Rulemaking: Time to Review Proposed Regulations & Consider Public Comment

Post author By Lindsey Downs
Post date August 3, 2022

July brought us the next chapter chronicling the U.S. Department of Education rulemaking process. WCET and the State Authorization Network (SAN) have been following the rulemaking process, which began with the preview of the second Biden administration negotiated rulemaking committee, the Institutional Programmatic Eligibility Committee, in January 2022. Since then, we have shared news and analysis primarily as the rulemaking addressed digital learning. In late June, we shared an update  regarding the rulemaking as it addressed issues of licensed professions and reciprocity.

Today, we will highlight the most recent news: the release of the Notice of Proposed Rulemaking (NPRM) for two sets of proposed regulations subject to public comment. We will address some specific issues found in the most recent NPRM and share how and where you may provide public comments pertaining to the proposed regulations.

Status Update

There have been several releases of proposed regulations for public comment in recent weeks including:

  • From the Fall 2020 Affordability and Student Loan Committee, Borrower Defense related proposed regulations were released on July 13, 2022 with a comment period through August 12, 2022.
  • Regulations for Pell Grants for incarcerated students addressed during the Fall 2020 rulemaking were released July 28, 2022, along with 90/10 Rule and Changes in (Institution) Ownership regulations with a comment period through August 26, 2022.
  • Although the Department submitted proposed regulations regarding Income Driven Repayment (IDR) to the Office of Management and Budget (OMB) for review in April 2022, the Department has delayed the release of the proposal of these regulations for later this summer.
  • As we reported in June, the OMB website posted updates of the expected release timeframe of April 2023 for proposed regulations for the remaining issues that were raised in the Winter 2022 rulemaking meetings. These issues include Gainful Employment and Certification Procedures. As you may recall, the Certification Procedure issue included proposed increased requirements for programs leading to a professional license or certification and as well as agreements for state authorization reciprocity. So, we likely will not hear more about them until next year.

Changes in Ownership – Modification of Definitions found in 34 CFR 600.2

For many economic and regulatory reasons, there has been a recent increase in changes of ownership or control of institutions. Of particular interest to the Department is the uptick in forprofit institutions seeking to change their status to that of nonprofit institutions. The Department clarified its expectations and processes on these transactions.

Included in their actions are changes to several definitions. While these changes were proposed with the “changes in ownership” issue in mind, the definitions are universal and could have far-ranging impact.

The proposed changes include:

a computer keyboard
Photo by Marta Branco from Pexels
  • Main Campus – Oddly, there was no official definition of “main campus” until now. Among other factors, it is the “the primary physical location where the institution offers programs.”
  • Branch Campus – The Department continued the  requirement that a branch campus be a separate location and that it has certain operations that are independent from the main campus. Newly added requirements are that the branch campus be part of the same ownership structure and be approved as a branch campus by the Department.
  • Additional Location – The Department continued the requirement that the location be separated geographically and that it offers at least 50% of a program. Newly added requirements include that they be part of the same ownership structure and participate in Title IV disbursement through the main campus.
  • Distance Education – The provisions that went into effect just last year remain unchanged. The Department proposes adding:
    • For institutions offering both on-campus and distance programs, the distance programs are “associated with” the main campus.
    • For institutions offering only distance programs, the institution is located where its administrative offices are located and approved by its accrediting agency.
    • *Note these additions will not impact locations at a correctional institution.
  • Non-profit Institution – Additional provisions regarding who and how a former owner may profit and the setting of a “fair market” value.

Current versions of these regulations can be found in 600.2.

Potential Impacts Outside of “change of ownership”

Look for more analysis from us on these definitions as we have some worries that these rules may have unintended impact outside of the “change of ownership” framework. For example, the “associated with” concept for distance education was introduced with the following reasoning: “This addition clarifies how an institution’s programs offered through distance education or correspondence courses should be considered in the context of reporting students’ locations…” We worry it will have the opposite result without careful and comprehensive guidance.

The big concern is that the definition of distance education additional language, by supposedly clarifying reporting of students’ locations, addresses location differently than what is required for purposes of state authorization required by 34 CFR 600.9(c).

photo of college campus
Photo by Casey Olsen on Unsplash

As we know, the institution is required by 600.9(c) to meet state requirements for it to be legally offering postsecondary distance education or correspondence courses in that State where the student is located or to participate in a reciprocity agreement. The institution is responsible for the determination of student location and to share the process of determination with the Secretary upon request. The purpose of these requirmentsis to ensure student consumer protection where the student is physically located. This language about determining location is repeated in the context of professional licensure notifications in 34 CFR 668.43(c)(3)(ii). This is troubling and confusing with potential conflicts with state oversight! Again, watch for more analysis from us.

90/10 Rule

For years, forprofit institutions have been responsible (by law) for obtaining at least 10% of their revenue from sources other than Title IV Federal Financial Aid. However, the fact that other forms of federal student aid counted in the 10% was seen as a loophole that made for-profit institutions excessively dependent on aid that is financed by taxpayers.

The proposed 90/10 regulations amend 34 CFR 668.28, Non-title IV revenue (90/10), in order to implement recently enacted Federal law through the American Rescue Plan Act of 2021. The newly enacted Federal law expands the sources of revenue to include more than just Title IV aid. The new regulations are developed as proposed to implement the new Federal law by identifying other sources that cannot be included in the 10% including veterans and service member tuition benefits.

The regulations, as proposed, reached consensus by the negotiators in the rulemaking committee in March 2022. Therefore, the language as voted upon was released as the proposed regulations. The intention of the regulations is to change how for-profit institutions calculate and report the percentage of the revenue that comes from other sources. New sources are to include all federal education assistance including grants for tuition and fees including GI Bill aid as well as other Federal military benefits. The Department will communicate the list of programs required for inclusion in the Federal Register and update that list as needed.

Pell Grants for Incarcerated Individuals

Congress established eligibility for Pell Grants for incarcerated individuals enrolled in qualifying programs through the Consolidated Appropriations Act, 2021. The language for the regulations negotiated in Fall 2021 came to consensus by the negotiators and thus are moving forward as proposed regulations to implement Federal law.

Specific to issues we have recently discussed affecting programs leading to a license or certification (such as in the delayed Certification Procedures regulations), we think the Department is expressing their view of the importance of regulatory direction addressing programs leading to a license or certification. We note that the proposed language also includes adding “make available” notifications, that we commonly describe as public notifications, to current regulations for Institutional Information, 34 CFR 668.43, regarding whether there are state prohibitions to licensure or certifications for formerly incarcerated individuals.

Proposed regulation 34 CFR 668.236 Eligible prison education program indicates that:

 An eligible prison education program means an education or training program that –

(g) Satisfies any applicable education requirements for professional licensure or certification….. in the State in which the correctional facility is located or, in the case of a Federal correctional facility, in the State in which most of the individuals confined or incarcerated in such facility will reside upon release as determined by the institution not less than annually based on information provided by the oversight entity.

Proposed regulation 34 CFR 668.43 (a)(5)(vi) Institutional Information

(vi) If a prison education program, as defined in 34 CFR 668.236, is designed to meet educational requirements for a specific professional license or certification that is required for employment in an occupation (as described in § 668.236(g) and (h)), information regarding whether that occupation typically involves State or Federal prohibitions on the licensure or employment of formerly incarcerated individuals in any other State for which the institution has made a determination about State prohibitions on the licensure or certification of formerly incarcerated individuals;

Public Comment on Proposed Regulations

a comment box

Timeframe:

Who should comment?

Your voice matters!

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.

Submit Comments

How do I comment?

Each NPRM announcement provides directions on how to comment in the “Summary” section of each notice. You are directed to submit comments via that Federal eRulemaking Portal at regulations.gov. At regulations.gov under “FAQ,” you will find the instructions for finding a rule on the site and submitting comments.

Please note that the Department will not accept comments submitted by fax or by email or submitted after the comment period deadline. You are advised to include the Docket ID at the top of the comments and submit your comments or attachments in Microsoft Word format.

What should I say?

Here is your opportunity to ask clarifying questions, show support for the language, express challenges that could have unintentional consequences on students, or raise other concerns. We suggest comments that are positive and provide helpful suggestions.

Next Steps

As previously shared, the comment periods will end on August 12 and August 26 depending on the regulations that you plan to address. The Department must review and respond to the submitted comments. The announcement of the final regulations will include the Department’s responses to the comments in the preamble of the Federal Register announcement. Final regulations that are released by November 1, 2022, will be effective July 1, 2023.

You can follow the progress of the rulemaking here:

Watch for more from WCET and the State Authorization Network (SAN)!

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