John Ebersole, president of Excelsior College, gives his views on where MOOCs currently stand on their trek to become avenues for students to receive college credit. This guest blog posting is part of a short series on MOOCs and follow last week’s “ACE’s First Review of MOOCs for Academic Credit.” We are pleased to welcome President Ebersole and thank him for his contribution.
Russ Poulin
Massive open online courses (MOOCs) have captured the attention of higher education and the political community in a way seldom seen. To many, the idea of access to instruction from world class institutions for free is the answer to a prayer. They offer the promise of a new form of instructional delivery that could take some of the heat off of higher education, and its ever rising tuition, as well as for the politicians whose cuts to state support have made necessary those increases. Hopefully, with MOOCs, state governors, legislators, and college administrators can find ways to promote universal access to higher education without having to worry about cost.
On the other hand, many within higher education are critical of MOOCs as vehicles for the creation of learning. They see any rush to recommend credit that can be used to satisfy degree requirements as premature. Partly as a result of this growing concern, only five MOOCs have been deemed credit-worthy by the American Council on Education, so far.
John Ebersole is President of Excelsior College – a private, non-profit institution serving nontraditional students by recognizing learning wherever and whenever it occurs.
What Have MOOC Students Learned and How was It Measured? Even where credit has been recommended, questions remain as to the extent that participants actually learned anything. While few question the capabilities of the sponsoring institutions or their faculty, the degree to which these reputational factors translate into learning is not clear. To date, very little attention has been given to the measurement of learning outcomes by MOOC providers.
Additionally, breathtaking attrition has called into question whether MOOCs are more akin to entertainment, or a 21st century text book, than to a serious learning experience. According to those in a position to know, one recent Coursera offering, initially enrolling more than one hundred thousand, had but seven take the final exam. When such a large number fall along the way, one must wonder about the quality of the journey according to those administering the exam (who have asked to remain anonymous).
Historically, a recommendation of credit for learning outside of an accredited institution, and the oversight of its faculty, has been held to higher standards than we see with MOOCs. Whether it be The College Board and its College Level Examination Program (CLEP), Educational Testing Service and its DSST portfolio, or the UExcel exams of Excelsior’s Center for Educational Measurement (CEM), college-level credit comes from passage of a psychometrically valid assessment, administered in a secure facility, operated by a third party. Those colleges and universities that accept such credit recommendations have come to expect nothing less.
At Excelsior, a typical subject assessment (i.e. college algebra) is created with input from subject matter experts drawn from multiple institutions. Working with CEM’s doctorally prepared psychometricians, exams are prepared for field testing. This process assures statistical reliability, predictability, and overall validity. Such exams are a far cry from those drawn from a text book publishers “test bank” or an instructor’s notes.
Assuring Academic Integrity is Essential
In addition to the validity of an assessment, it is also expected that it will be administered with attention to student identity and security for the instrument itself. While some MOOC providers do verify the identity of those taking their course, and proctor their end-of-course examinations, little attention is being given the security of the assessment instruments. This could become a problem.
With the potential for thousands of exam takers from around the world, question banks need to be larger than for a homegrown instrument or a smaller population of test takers. ETS and Pearson learned this some years ago when the Test of English as a Foreign Language (TOEFL) was compromised by well-organized Asian students with near photographic memories.
To be clear, for an assessment’s results to be worthy of transcription and acceptance toward degree requirements, it should be:
Prepared with input from multiple subject matter experts who agree as to what constitutes an acceptable level of knowledge to warrant college credit;
Created and field tested by qualified psychometricians;
Based upon question/item banks sized to insure random item ordering (i.e., no two examinees receive an identical exam). [The fact that this is not yet a problem has more to do with high attrition than attention to scalability.];
Administered in a secure facility, where multiple forms of identity verification can be employed, including biometrical data.
MOOCs often Fall Short in their Assessments
This contrasts with what is seen from the major MOOC providers. A final examination, or assessment of learning, if provided, is typically prepared by the offering instructor. As one edX executive stated, “The fact that the exam comes from an MIT faculty member is the only validity we need.” This person is usually not trained in the preparation of statistically valid assessments and, in the eyes of some, has an inherent conflict of interest in evaluating his own work. Administration of those exams now offered is understood to involve remote proctoring employing an internet camera and/or various forms of identity assuring software.
At a time when the federal government, regional accreditors, and much of the academic world has shifted from the measurement of inputs (number of PhD faculty, ratio of students to instructors, books in the library, etc.) to the assessment of outputs, MOOC providers and their sponsors must increase their attention to the learning side of the ledger. No longer can or should we assume that a sufficient level of learning takes place merely because the instruction comes from a brand name institution, with a credentialed instructor. Today, there is an expectation that we measure actual learning. This is, admittedly, new, both for the instructional provider and for those who are asked to determine possible equivalency – the American Council on Education (ACE) and the National College Credit Recommendation Service (NCCRS).
But There is Hope for MOOCs
The good news is that this need not be a particularly difficult problem to resolve, assuming of course that learning is occurring and that we just need to do a better job of measuring. ETS, The College Board, and Excelsior have a combined inventory of exams that nears one hundred undergraduate subjects (upper and lower division). While most MOOCs have so far featured topics for which there isn’t an appropriate exam, the process to create one is not substantially longer or more complex than what is required to create and offer a course in MOOC format. In return for paying more attention to learning outcomes, and how they are measured, MOOC providers can not only help enhance the credibility of this pioneering effort, but also gain credibility in the eyes of critics. It can also provide those who complete their offerings with the credit they seek.
Over the next few weeks, WCET will publish a series of blog posts on Massively Open Online Courses. Given the amount of press that MOOCs have received over the past year, you must be wondering why we need more writings on the subject. Our guest blog posts will focus on implementation issues for institutions, including: the credit conundrum (are MOOCs credit-worthy?), lessons learned from those implementing MOOCs, and we’ll conclude with some overall observations and some (sometimes uncomfortable) questions. Thank you to Pat Book for starting the series in clarifying many of the misconceptions around ACE’s credit recommendations for five MOOCs.
Russ Poulin
Deputy Director, Research and Analysis
WCET
ACE as Academic Credit Reviewer–Adjustment, Accommodation, and Acceptance
In retrospect, it seems like a foregone conclusion that the courses Coursera self-selected for review would be highly likely to receive an ACE’s CREDIT® recommendation. And it is just that, a recommendation. Credit decisions remain the sole discretion of each educational institution that receives an American Council on Education (ACE) transcript.
ACE’s history in reviewing training for credit recommendations began in 1945 with the review of military training. It expanded in 1974 to include training occurring in corporations, federal agencies, associations, and other non-profit organizations. More recently, ACE has seen a real shift in the emergence of new, alternative educational vendors in the ACE review process, largely focused on subjects commonly included in lower division baccalaureate studies. These include the College Network, StraighterLine, DreamDegree Academics LLC, SOPHIA Learning, LLC, etc. While working at ACE, I was surprised to see that these unaccredited educational vendors now comprise a third of ACE’s CREDIT® clients and provide largely low-cost, accessible alternatives to college curricula. Clients pay for the ACE review and students not only pay the vendor but also pay ACE to receive their transcript for submission to the institution of their choice. ACE’s Center currently conducts close to 150 reviews yearly for the military and non-military clients.
ACE makes credit recommendation. Colleges make their own final judgement.
This activity is largely self-supporting within the ACE organizational structure and has not been very visible in the institution’s priorities until recently. MOOCs had the potential to catalyze ACE CREDIT’s expanded role and to generate substantial revenue from the envisioned sale of millions of transcripts worldwide.
ACE finds itself in the awkward position of advocating for the best interests of their institutional members while at the same time serving as a shadow accrediting body distributing the ACE imprimatur (defined by those very member institutions) to a host of newly emerging for-profit ventures whose mission and goals are very different. While ACE seeks to fend off federal policy requiring the acceptance of the kind of Prior Learning Assessment ACE itself provides to these competitors and others, its staff also advocate on behalf of students receiving ACE transcripts for their acceptance at member and non-member institutions, working with state policy makers around the country to inform them about the ACE CREDIT® and ACE military reviews. Given all this anomy, my experience at ACE suggests three rubrics to define their strategy—“adjustment” of their CREDIT review processes, “accommodation” to the demands of new providers, and “acceptance” of just about every paying client that walks in the door without regard to how it benefits its members.
The First MOOC Review: Adjustment and Accommodation
While serving as Assistant Vice President at the American Council on Education this past year, I led the unit that conducted the first review of MOOC courses offered through Coursera‘s platform. The universities involved included the University of California Irvine, Penn, and Duke. This was a pilot project tied to a Bill and Melinda Gates Foundation Grant I wrote for ACE to study MOOCs. The review was conducted using the process that ACE currently uses in its reviews of workplace training.
Reviewing academic courses taught by faculty at top tier universities was a new venture for ACE as its CREDIT recommendation service was not designed for nor (to my knowledge) ever had been deployed for this type of review. ACE leadership was anxious, as was Coursera, to address the major topic of discussion last year about whether or not MOOCs were credit-worthy. My team conducted the review in January 2013, after conducting an onsite review of Coursera’s operation in the Fall of 2012. The review was conducted virtually with four faculty reviewers over a one week period. While we typically guarantee results within 30 days from the review, in this case, we produced the results within 15 days and this became a major news story.
The rules that ACE had to bend to accommodate the review included the requirement that the provider be in business for at least three years. The review was conducted on Coursera’s one-year anniversary. Since the courses were developed and taught by faculty at universities with considerable stature and history, this waiver was made. Another rule that needed to be adjusted was whether or not the course had been offered at least once in the past. In some cases, the courses had not yet been offered or were not fully developed.
Who are the Evaluators?
Key to the ACE review process is that all reviews are conducted by faculty, not ACE staff. ACE staff support the process logistically and assist the provider in preparing for the faculty evaluators review according to the ACE Handbook, but ACE staff do not participate in the review itself. Over the decades in which these reviews have been conducted, a substantial database of faculty reviewers has been developed with the supposed expertise to review the type of training you would expect to see in the military or in a corporate or agency setting.
To become a faculty evaluator an individual must be actively teaching college-level courses at an accredited institution—they can be adjuncts—and have a minimum of five years teaching experience. They also must be receptive to recommending academic credit for learning that occurs in an extra-institutional setting. Faculty apply online and ACE staff enter them into the faculty database if they meet the minimum requirements. As reviews get scheduled, staff search the database for the content expertise and select faculty to participate in a review whose schedules match the date of the review. An effort is made to pair a faculty member new to the ACE review process with a more experienced faculty evaluator since no formal training program is provided for these faculty evaluators. Faculty are provided with a detailed Handbook and become part of a Faculty Review Team led by a National Coordinator who oversees and guides the faculty review process. Sometimes that National Coordinator is an ACE staff member and sometimes an experienced faculty member.
The compensation for conducting these reviews is $400 for the faculty reviewer plus all travel expenses if an onsite review. The National Coordinator, if a faculty member, receives an extra day of compensation for their responsibility in preparing the final report. The reviews typically are conducted onsite where the organization under review has prepared materials for the faculty to review, including training materials, syllabi, assessments, and facilitator resumes.
Piloting ACE CREDIT Review on MOOCs
To engage this process in a review of courses taught by faculty at top tier academic institutions made demands on ACE’s Credit Review Process that had not been encountered in the past. My prominent concern was finding peer faculty reviewers in the faculty database and, as one would expect, those were far and few between. Therefore, I personally made a nationwide call for faculty at top tier institutions to encourage them to apply to be faculty reviewers and we scoured the database for faculty who were full-time professors, or were at top tier institutions or who had received their academic preparation at top tier institutions. I used my continuing education colleagues as the contact point at institutions.
The response was fairly low and typically included faculty not at the main campus but at a branch campus of a top tier institution. Having worked for 12 years at a top tier institution, I realized that there was virtually no incentive for faculty at these types of institutions to participate in this type of review. First, the compensation is not competitive. Reviews typically require three days for onsite reviews, two involving travel days, but the faculty are only paid for one day plus all expenses. The time commitment is a second major disincentive, taking faculty away from higher value research activities.
Even with those barriers, reviewers were identified.
The initial courses subject to ACE review were selected by Coursera in consultation with their partner universities. Coursera and the partner universities chose courses that were already offered on campus or were using content similar to an on-campus course. ACE required that the universities provide a written statement confirming for ACE that they agreed to submit their courses to the ACE CREDIT review process since the review was conducted with the course hosting platform, Coursera.
ACE Review Process As part of the ACE review process, faculty are charged to consider recommendations based not on their institution, locale, or region, but to critically appraise materials from a national and professional perspective.
The Faculty Review Team was led by the director of ACE CREDIT® and included four faculty with teaching experience. Generally, faculty review teams consist of faculty across institutional types who are current in the relevant academic disciplines. In this case, faculty from public and private four-year institutions were used, one an adjunct professor of math.
Depending on the course content, a minimum of two faculty reviewers are used for each course, sometimes expanding to three or more if the content includes substantial material from multiple disciplines. In this case, there were two faculty reviewers per course. Faculty on the team worked together to review the “content, scope, and rigor” of the course. They reviewed the course syllabi, any texbooks, assessment methods, any student or instructor guides, laboratory projects, if relevant, instructional materials and curriculum vitae of instructors involved in developing and delivering the course to assess their qualifications.
ACE staff conduct the pre-site review for organizations seeking an ACE review. Since these organizations are not primarily in the education business, they often need considerable coaching on what to expect in an academic review, including basics about development of a syllabus. The pre-site review in the case of MOOCs was a review of the course platform, Coursera (at their Mountain View, California site), paying particular attention to student records and their security.
In the review process faculty focus on course content and learning objectives. As they examine the depth and breadth of material and level of difficulty, they consider the applicability of the content to postsecondary programs. Importantly, faculty examine whether the assessments of learning match the learning objectives in terms of depth, breadth, and level of difficulty. One of the issues faculty frequently encounter in these reviews is that the learning objectives are at a higher level than the assessments resulting in a recommendation for lower division work.
Reviews are typically conducted in a face-to-face format with the organization at considerable cost due to the travel and hosting expenses of the review team. Most organizations do not have the internet capacity to host an online review. ACE created a virtual course review capability recently for those who do have the capacity and now some 20% of reviews are conducted with faculty distributed across the country and using a SharePoint platform to conduct the review. In the Review, faculty are instructed to consider learning outcomes, course intensity, pre- and post-course assignments, instructor qualifications, and participants’ academic/work-related experience. The faculty use standard and consistent review guidelines and ultimately must find consensus on any credit recommendations they provide, including the level of the course (vocational, undergraduate lower division, undergraduate upper division, or graduate) and the amount of credit to recommend.
Faculty reviewers are also responsible after the review is conducted to write the course exhibits for ACE’s online guides—The National Guide and Military Guide Online. Institutions rely on these guides when considering ACE recommendations as transfer credits for enrolling students.
Acceptance of Coursera’s MOOCs Faculty used ACE review criteria to evaluate MOOCs offered through the Coursera platform. All five courses reviewed received credit recommendations based on ACE’s review criteria. The five courses received math and science recommendations, one at the developmental math level, that is, three-credits of pre-college, three at the lower division baccalaureate level, all three credits, and one two-credit recommendation at the upper division baccalaureate level. Faculty reviewed all course exhibits including learning outcomes, competencies, and assessment methods. Faculty made suggestions regarding perquisites and offered other notes. While ACE has recommended academic credit, it is up to each university or college to review these credit recommendations and determine how they may align with their general education requirements or degree programs. There is no guarantee that any university of college will accept the ACE credit recommendations.
What does this mean?
In retrospect, as noted in the beginning, it seems like a foregone conclusion that the courses Coursera self-selected for review would be highly likely to receive an ACE CREDIT® recommendation. They were courses developed by faculty and already reviewed for credit in their university system in some cases and just being offered in a new delivery method albeit to a massively scaled audience.
The review process doesn’t evaluate learning outcomes, but is a course content focused review thus obviating all the questions about effectiveness of the pedagogy in terms of learning outcomes. The fact that they can be credit worthy, therefore, may not be a surprise, but it is useful to know that experienced, disciplinary faculty perceived them as credit worthy. ACE announced in their original press release that they plan to continue to work with Coursera and other MOOC providers to evaluate additional courses in the coming months. As a result of reaching out to post-traditional learners to promote educational attainment, ACE should see a substantial increase in their transcript revenue.
Another component of the Gates Foundation grant is underway with the University Professional and Continuing Education Association as they pilot acceptance of ACE CREDIT® from MOOCs by universities and colleges, especially those serving the demographic of low income, young adults. Credit recommendations are one thing, their acceptance in meaningful ways by institutions to further the academic aspirations of vulnerable students is another. MOOCs currently serve largely an international audience who already hold college degrees and have reasons other than degree attainment motivating them. The jury is still out on the value for the vast majority of American students who need developmental education and/or are seeking affordable access to college credentials. The integrity of the ACE CREDIT® review process, grounded in peer faculty review, is of critical importance to those institutions who depend on their recommendations as well as to students whose academic goals can be accelerated by Prior Learning Assessment.
Patricia Book
WCET Fellow
(Former Assistant Vice President at the
American Council on Education)
In recent weeks I have received several inquiries about that status of SARA – the State Authorization Reciprocity Agreement. Since the national meeting in April, there has been activity, but it has been slower than hoped. To be clear, I am not in charge of SARA, but I have been part of many discussions and planning sessions. This update is not the official final word on anything. It reflects my understanding and opinions of what is happening. In a related issue, I’ll report on recent legislation introduced in the U.S. House of Representatives.
A foundation is very likely to fund this work. Due to a variety of issues that have more to do with logistics and timing (and not the quality of the proposal), the funding has been delayed. The foundation is working closely with the regional compacts and there is hope that the funding will be announced soon. In anticipation of the grant, NEBHE and MHEC have already advertised for staff to support the SARA work in their regions.
SARA is ready to partner with states, but is awaiting a grant and work on final details
Meanwhile, work continues, but staff is really needed to work through the next level of details.
Testifying to the U.S. Department of Education
In April, the U.S. Department of Education announced a new round of negotiated rulemaking and state authorization is one of the issues that they are considering. David Longanecker (president of WICHE) testified at an open hearing. Speaking on behalf of the four regional compacts, he spoke in favor of SARA. I also testified. While I briefly spoke in support of SARA, I also covered some issues the Department should consider if it reinstates the state authorization regulation. I saw the panel take notes when I mentioned that most institutions are still not fully in compliance.
Letter from State Regulators
I was on a panel at the NASASPS meeting in April 2013 to talk about SARA. NASASPS mainly serves state regulators and they still have concerns (and some misconceptions) about some of SARA’s provisions. They were invited to write a letter to the regional compacts detailing their concerns. Their subsequent letter raises legitimate issues. On behalf of the regional compacts, David Longanecker wrote a response that began to address many of the items they cited. He concluded by saying: “We will continue to work closely with NASASPS as our implementation plan moves forward, and we fully intend to include representation from the members of your organization in the advisory structures for all our organizing entities.”
National Council for SARA
Nominations for individuals to serve on the Board of the National Council on State Authorization Reciprocity Agreements (NCSARA) closed on July 15. The role of the Board (taken from the nomination letter) will be to “advocate for the expansion of the agreement and adhere to three core principles of operation: maintenance of a limited role within the overall governance of the agreement, responsibility for communicating information to the field, and representativeness of all stakeholders.” The Board will be “sufficient in size to assure that the perspectives of all stakeholder groups will be represented on the board, but small enough to be an effective working coordinating board.” Selection of Board members is expected to occur in August.
Regional Compacts to Work with States Once staff is hired, the four regional compacts assist states in their regions in determining if and how to implement SARA in their state. There is a tentative plan for each region to hold an informational meeting this fall, but no dates have been set. While there will not be model legislation (since states differ so much), there will be a checklist of what each state’s laws and regulations should include to allow it to participate in SARA.
The necessary steps will need to be tailored to each state. Many states will need some form of legislation. With some states requiring possible legislative language to be under construction (if not finalized) by October or November of this year, I hope that the window of opportunity is not missed in any state.
What about those “Other” States?
New Jersey, New York, and Pennsylvania are not part of any of the regional higher education compacts, but there is a mechanism for them to play in SARA. Here is my understanding on the status in each state:
New York — The state’s higher education leadership has researched options, but their discussions are still in the nascent stage.
New Jersey — There has been extensive discussions among college presidents in the state and with the Secretary of Higher Education. They appear to be well-organized and ready to proceed.
Pennsylvania — The Pennsylvania State System of Higher Education (PASSHE) was leading an effort for the state to join MHEC as a full member (with benefits beyond SARA), but this is still in the discussion stage.
Going Forward with SARA
I expect that once it is announced that the foundation has approved the grant that activity will move at a very quick pace with much activity this autumn. Watch for much more news in the next twelve months as this will be a crucial start-up year for SARA.
House Introduces Bill to Repeal State Authorization
The U.S. House of Representatives recently introduced a bill (H.R. 2637) that, if enacted, would repeal state authorization at the federal level. Additionally, it would prevent the Department of Education from promulgating any new rules on state authorization until the new round of reauthorizing the Higher Education Act is completed. The bill also addresses the credit hour, gainful employment, and other regulations introduced by the Department of Education.
In brief, the bill has a good chance of passing the House of Representatives, but will assuredly stall in the Senate as a similar bill did in the last few years. Even if it were signed into law (which is highly unlikely) it would have no impact on the many state laws already in place. States would still expect institutions to comply with their laws and regulations.
We will continue to keep you updated on all these activities.
Russ
Russell Poulin
Deputy Director, Research and Analysis
WCET – WICHE Cooperative for Educational Technologies rpoulin@wiche.edu
Twitter: wcet_info and RussPoulin
As a loyal follower of WCET’s discussion threads over the years, I’ve had an opportunity to chime in on various topics, and the use of online tools for student collaboration is probably at the top of my list of issues with which I have some familiarity. This post will be an extension of an earlier conversation with Russ Poulin, and will permit me to elaborate a bit more about my online classroom experiences with Google Drive, Google’s open platform for collaborating “in the cloud” and Google’s Hangouttool for virtual face-to-face meetings.
Dr. Brian Janz, University of Memphis, suggests using open tools as they can be used by the student outside class and that they increase engagement with and among students.
First a little background: After a 10-year stint in the IT industry and a 4-year stint for a PhD, I’ve spent the last 18 years teaching at the University of Memphis’sFogelman College of Business and Economics, where I teach in the Management Information Systems (MIS) Department. Seven years ago, I was asked to develop the first online course for the college to determine whether online education made sense for our MBA program. Since that time we’ve gone on to develop an online MBA degree, along with 3 online undergraduate programs, and I’ve gone on to develop 3 different online courses.
As one of my main research interests focuses on how teams collaborate and cooperate in the workplace, I have always sought to incorporate online tools in my courses that not only help students collaborate any time, any place, or any way they might want to, but also give them experience with real-world tools that they may actually encounter in the workplace (the vast majority of my students work full-time, so these encounters often happen almost immediately). I also try to be sensitive to choosing tools that don’t cost an arm and a leg (with “free” being the best option), that are also easy-to-use, and easy to maintain. Last, but certainly not least, I am always on the lookout for tools that help raise the level of student engagement in the online environment, as I often see engagement as being the Achilles’ heel of many online teaching efforts. Google’s open platform product, Drive (previously known as Google Docs) has always done well on these dimensions, and I’ve required its use since I started teaching online. Allow me to elaborate a bit.
Working in the Cloud
I like open cloud-based platforms like Drive since this is the future of computing for all of us, regardless of occupation, industry, etc. As most of us know, cloud computing is one those “next big things” that has already arrived, and requiring students to use cloud-based tools helps them in class and gives them a jump-start for how they’ll work in the real world. To that point, it is not uncommon for me to receive dozens(!) of student comments every semester expressing how Drive has become an indispensable tool for them in other courses or in their current jobs (remember, most of my students are working full-time).
One of the reasons cloud-based tools and services have become so popular concerns their maintenance. It’s not that they need less maintenance, it’s that the users are not responsible for performing or worrying about the maintenance. In this case, it’s up to Google to make sure that Drive’s tools are always available and as error-free as possible. In an era where IT organizations of educational institutions are so resource constrained, it’s nice not having to bother your colleagues over in IT or worry about whether your IT help desk is as concerned about your software problem as you are.
Finally, cloud-based computing provides two benefits that really resonate with students: data backup and data portability. No longer do students have to offer up the time-honored chestnut about not having their homework because of crashed hard drives. Google see to it that students always have access to their data. Similarly, students don’t have to rely on just one computer to access their work. With their documents stored in the cloud by Drive, they can access their work 24/7 from any computer with an Internet connection, e.g., computer labs, library PCs, even a classmate’s computer.
The Google Drive Toolkit
I am quite impressed by the breadth of tools available within the Drive platform, and it just keeps getting better. Of course there is the Word-like word processor that is the most well-known tool in Drive, but there is also a very serviceable Excel-like spreadsheet tool, a very functional PowerPoint-like presentation tool, a fine Visio-like drawing tool, a Survey Monkey-like survey tool (called a “Form” in Drive), and what I consider a best-of-breed video conferencing capability called a Hangout (while not strictly speaking a Drive tool, it is in the Google family…more on this later).
Besides being feature-rich, one of the main benefits of the tools available in Drive lies in the ability for multiple people to simultaneously work and comment on a file in real-time. For example, a group of students can all view the same document, spreadsheet, or presentation on their respective computers, provide changes to content, or comment on the content for everyone else to see, at the moment the changes are made. This real-time collaboration provides an opportunity for online students to truly engage with their classmates, much like they would if they were huddled around a table in the library working together.
And it gets better. Not only are Drive’s tools sufficiently feature-rich and collaboration-friendly, they are free! This last bit is really important if you want to give your students a level playing field in terms of what software they can afford to use. In my case, should my working students, with employer-provided laptops equipped with the latest and greatest purchased software have an advantage over non-working students that have to pay for their own computers and software? I avoid the debate completely by requiring that they all use the same free software to do their coursework for me. Interestingly, many of the students with access to purchased software often find they prefer the free tools available in Drive.
And since we’re talking about free vs. purchased software, let’s address the, “Yeah, but my purchased software has so many more features than the free stuff.” In all my years in the IT industry and teaching IT concepts in higher education, I’ve come to know one thing for sure: we all need/use just a fraction of the features that are available to us in most software packages. Most “pedestrian” users probably use less than half of the features in a typical purchased piece of software, in most cases, much less. Even “power users” don’t need all the features available to them. I’ve found that the tools available in Drive embody almost all of the most important features typically needed by today’s knowledge worker. Are they perfect? No, but in the case of Drive, you don’t get what you pay for, you get much, much more that you don’t pay for.
Oh, and just a few words about ease of use. I have found all of the tools to be fairly straightforward to use, as is. If your students have used word processing, spreadsheet, and presentation software before, they’ll have no major learning curves to climb. However, if you have students that are new to these kinds of productivity tools, there are always plenty of YouTube videos available that can serve as helpful tutorials for all of Drive’s tools. Aside from basic “getting started” instructions, I have yet to find that I’ve needed to create my own tutorial for any of the tools available in Drive.
On a related note, I’ve learned over the years that students often try to do their initial work with some other piece of software that they’re comfortable with and then convert it to the Drive equivalent before turning it in, e.g., creating a document in Word, and then converting it to a Drive document. While this can be accomplished with Drive, it is not uncommon that some formatting may get lost or misconstrued during the conversion process. What most power users of Drive advocate is to do your work completely in Drive and avoid any potential headaches related to file conversion.
Student Engagement: The Holy Grail of Online Education?
I typically teach the required IT course for all of our MBA students. In a given semester, I usually teach an online section of the course as well as an “on-ground” section of the course. And while I have tried to design the course to give all students as similar a learning experience as possible – requiring the same readings, assignments, due dates, exams, etc. – the courses differ in lecture format (face-to-face for on-ground vs. narrated lectures for online).
In talking to students, I learned early on that online students yearned for more engagement, not only with me, but also with their classmates. As a result, I have discussion forums just for students to socialize (for what it’s worth, I’ve used D2L, facebook, and now LinkedIn), and I’ve also used the collaboration features of Drive as well as various video-conferencing tools in an attempt to fill the need for face-to-face interaction. Here again, an open-platform tool from Google – the Google+ “Hangout” – has proven itself to be a great option when considering ease-of-use (click and go, especially if you’re a Gmail user), features (up to 10 people can participate at once, share screens, captures screens, etc.), and price (free again!). In comparison to fee-based videoconferencing tools and services that often require institutional licensing, I’ve found Hangouts to be easier, cheaper, and just plain better.[youtube=http://www.youtube.com/watch?v=ahy3uRzRG9w]
I require online students to give Hangouts a try when they are working on their group-based projects, and I also encourage students needing to meet with me to do so over a virtual office hour with Hangout. I also suggest that they give them a try when communicating with geographically-dispersed friends and family.
Finally, I require that all undergraduate online students meet with me via a Hangout during the first week of class so I can assess their readiness to undertake online learning as well as gain their verbal commitment (for what it’s worth) that they will do what’s necessary to keep up with the course requirements and contact me if they’re having problems. There does seem to be something about looking a student in the eye (and having them look at me) that really gets through to them, even if it’s on a PC screen.
As with Drive, students often tell me at the end of the course that they enjoyed using Hangouts, and that they have incorporated it into their personal lives. I think this is a good thing, as virtual video meetings have become commonplace in today’s travel-restricted working world, and knowing how to effectively communicate over a webcam takes some getting used to.
Advice to Faculty
You owe it to yourself to acquaint yourself with these open-platform tools. If possible, try to do some real collaboration with friends, family, or colleagues. Play around with all that Drive has to offer in terms of documents, spreadsheets, presentations, forms, and drawings. Go ahead and give a Google+ Hangout a try. I’m sure you’ll find that there is room for cloud-based open platform tools in your online bag of tricks!
Brian Janz
First Tennessee Professor of MIS
Associate Director, The FedEx Center for Supply Chain Management
Fogelman College of Business & Economics
The University of Memphis www.brianjanz.com
In May, WCET sought your input regarding the U.S. Department of Education’s announcement of a new round of negotiated rulemaking. Such “rulemaking” is the first step in the Department possibly creating new regulations or refining old ones.
Most notable to the postsecondary distance education community was the renewed interest in the state authorization for distance education regulation. It is my suspicion that they would not have raised this issue if they did not see this as the first step in reinstating the federal regulations that had been vacated by the federal courts in the last few years.
Also of note is the Department’s renewed interest in solving the financial aid fraud for distance education problem. This is big money and a serious issue. The other items that they listed for consideration included: cash management of federal financial aid funds, state authorization for foreign locations of institutions located in a state, clock-to-credit hour conversion, gainful employment, and changes from the Violence Against Women Reauthorization Act of 2013.
Russ Poulin delivering testimony to the U.S. Department of Education’s Negotiated Rulemaking Hearing on May 30.
David Longanecker, president of WICHE, and I provided testimony at the Department’s hearing held in San Francisco, CA on May 30. Dr. Longanecker focused solely on the history of and the role that the regional higher education compacts are playing in the creation of the State Authorization Reciprocity Agreement. I focused on fraud, state authorization for distance education, and state authorization for foreign locations. I also gave an overall philosophy about distance education regulation that I hope will help them to think differently in a changing world.
Thank you to all of you who provided thoughts and comments. They were most appreciated and very helpful. Below is my testimony. We will continue to follow any further developments.
May 30, 2013
Wendy Macais
U.S. Department of Education
1990 K Street, NW, Room 8017
Washington, DC 20006
Dear Ms. Macais:
WCET, the WICHE Cooperative for Educational Technologies[1] submits the following comments in response to the U.S. Department of Education’s announcement posted[2] in the Federal Register on April 16, 2013 on its intent to establish a negotiated rulemaking committee. Our comments will be limited to the following topics that were announced as being under consideration for action by the proposed negotiated rulemaking committee:
“…proposed regulations designed to prevent fraud and otherwise ensure proper use of Title IV, HEA program funds, especially within the context of current technologies” as previously announced in a notice issued by the Department in May of 2012[3].
“State authorization for programs offered through distance education or correspondence education.”
“State authorization for foreign locations of institutions located in a State.”
WCET’s mission is to accelerate the adoption of effective practices and policies, advancing excellence in technology-enhanced teaching and learning in higher education. Our members (institutions, state agencies, multi-institution consortia, non-profit organizations, and corporations) come from throughout the United States. WCET operates as a unit of the Western Interstate Commission for Higher Education[4], which is a non-profit, Congressional compact of 15 western states.
Move Regulations from Input to Outcomes Measures
There has been considerable attention by members of Congress, their staffs, and U.S. Department of Education on the developments in distance learning across colleges and universities of all types. Given the growth in this type of learning, such scrutiny is to be expected. In creating regulations, there is a tendency to bifurcate programs, courses, and students into two categories: “distance education” and “traditional.” Such a dichotomy no longer fits the educational reality. Faculty increasingly use technologies in “traditional” classes and classes of all types. There are changes in the amount of face-to-face time between faculty and students as courses become “blended” or “flipped.”
Instead of a bifurcation based on “distance” vs. “traditional,” we now have a rich array of combinations and options of how much technology is used in a course and how much face-to-face instruction occurs. Similarly, students can choose to be “distance” one term, “traditional” the next, and mixed the following term.
WCET suggests a new policy framework regarding regulating distance education and educational technologies:
Regulations should not differentiate by mode of instruction unless the regulations are actually about the tools used in the mode of instruction.
For example, it makes sense to regulate as to whether technologies are accessible or not. It does not make sense to make financial aid distinctions based upon on how the student receives instruction.
Stop worrying about the inputs. The Department’s current definition of “distance education[5]” includes many technologies. Given the rapid change in technologies, any such list is out-of-date as soon as it is published. We applaud the move to outcomes and competency-based measures as a replacement for measures based upon mode of instruction.
Preventing Fraud in Distance Education Programs
in September 2011, the Office of Inspector General issued an Investigative Program Advisory Report on Distance Education Fraud Rings[6]. In October 2011, the U.S. Department of Education released a ‘Dear Colleague’ letter as an “Urgent Call to Action” on “Fraud in Postsecondary Distance Education Programs.” In May 2012, the Department issued an announcement of an intent to establish a negotiated rulemaking committee[7] with the intent of “considering suggestions for regulatory changes to further help institutions combat fraud and protect students and taxpayers from fraudulent activity.” The work begun with the May 2012 announcement now continues through the current process.
WCET and its membership stand firmly behind the Department of Education in combating fraud in distance education programs. We offer suggestions on specific details of this work.
Promote Education on Combating Fraud for Staff and Faculty
Preventing fraud often falls to a limited number of financial aid and instructional technology staff. While they bear the bulk of the burden, it is often the faculty or other student service personnel who first note anomalies in “student” behavior. Their input would be helpful in creating campus “early warning” systems. WCET encourages the Department to work with distance education organizations to continue in identifying best practices in identifying fraudulent activity and disseminating those practices to key personnel. WCET is interested in assisting with broader educational outreach to raise awareness of methods to prevent fraud.
Do Not Differentiate Cost-of-Attendance by Mode of Instruction
The Office of Inspector General’s report states: “Since 2001, OIG raised concerns about the cost-of-attendance calculation for distance education students because an allowance for room and board does not seem appropriate to these programs, which are largely designed for working adults.” Subsequently, a budget proposal from the Administration included a proviso to eliminate “room and board” and “miscellaneous” expenses from the Pell Grant cost-of-attendance calculations for distance students.
WCET strongly objects to this recommendation. The result would be to punish the innocent.
While many distance students are working adults, many are traditional age students. Adults might quit their jobs or reduce their workload to enroll in an online program. Commuter students often fit the same “working adult” profile, yet they would maintain eligibility for these same costs. Imagine twins living in the same house, both taking a full load. If one twin took all his courses online, he would have a reduced cost-of-attendance. If his twin brother took the same classes, but took one one-credit course face-to-face, that second twin brother would receive credit for room, board, commuting, and computer costs. This is simply inequitable and would have the greatest impact on those with the highest need. If the concern is about “working adults” making too much money to be eligible for Pell, then base the criteria on those considerations regardless of how the student receives instruction.
Don’t Confuse Financial Aid Fraud and Academic Integrity
Fraud is the action of someone (usually in a fraud ring) using fake, appropriated, or conspirators’ identities to deceive an institution for financial gain. Academic integrity is an act by a student (whose identity is known) to obtain a better grade. Fraud is a criminal act and many of the preventive measures are upfront. Academic integrity is a violation of policy and requires on-going vigilance throughout a course.
WCET worked with the University of Texas TeleCampus and the Instructional Technologies Council to create the “Best Practice Strategies to Promote Academic Integrity in Online Education[8].” This week we published an “Academic Integrity Self-Check[9]” to help institutions work with faculty in curtailing cheating. WCET continues to have an active workgroup focused on academic integrity. Beyond proctoring and technical solutions, WCET’s recommendations include many that focus on instruction, including: improved assessment techniques, group assignments, and frequent interaction.
While financial aid fraud and academic integrity have some similarities, be wary of one-size-fits-all solutions. High barriers for proving a student’s identity in applying for aid may be appropriate, but could have a chilling effect if the student has to repeat it for each interaction within a course.
WCET Supports EDUCAUSE’s Recommendations on Technical Strategies to Combat Fraud
Subsequent to the May 2012 announcement on the Department’s intent to create a negotiated rulemaking committee, comments were accepted on proposed methods to address financial fraud for distance programs. EDUCAUSE submitted comments addressing[10] the technical strategies issued in the Office of Inspector General’s report. WCET supports their comments as still being relevant.
EDUCAUSE suggests that tracking IP and email addresses may “assist in the identification of technologically unsophisticated fraud rings; however, those engaged in financial aid fraud in relation to distance education programs are likely to progress rapidly to the use of proxy servers and dummy e-mail accounts…” They also cite the cost and administrative burdens. WCET also suspects that many students already legitimately use multiple email and IP addresses and that “noise” will increase the analysis required to identify those in fraud rings.
EDUCAUSE also cites the difficulties in requiring distance students to physically appear as part of the admissions process. We concur that such a requirement would add a substantial burden to students and institutions.
As an alternative, EDUCAUSE suggests exploring its CommIT project[11], which “would enable students to navigate the myriad of systems and service providers potentially involved in applying for admissions and financial aid using only a single set of credentials. More importantly from the perspective of this discussion, it would extend such credentials on the basis of identity assurance on par with that of the financial services industry.”
State Authorization for Distance Education
In October 2010, the U.S. Department of Education issued regulation § 600.9(c)[12] requiring institutions to “meet any State requirements for it to be legally offering distance or correspondence education in that State.” Since that time, WCET has been active in educating institutional personnel on both the federal and state regulations. WCET’s State Authorization Network[13] is a service that connects institutions so that they are sharing knowledge about obtaining authorization and tracking compliance.
Allow Time for Compliance
Even though institutions are supposed to be following state laws and are supposed to be seeking compliance, relatively few institutions have all the approvals that are required. WCET conducted a survey earlier this year[14] in partnership with the University Professional Continuing Education Association and the Sloan Consortium on institutional progress toward compliance. Of the 206 respondents:
15% have all the approvals required.
52% have applied to one or more states.
33% have yet to gain approval in even one other state.
This demonstrates progress over our previous compliance survey from 2011. In that survey, 67% of responding institutions did not have approval in any state.
Additionally, states are not ready to handle another onslaught of applications. Processes in some states take a year or longer. With budget constraints, compliance staffs have been cut in some states.
Institutions may need at least two years to be in full compliance. A reissue of the “good faith” effort benchmarks would be useful. More specificity in the wording of the “good faith” effort would be needed to encourage institutions to progress through the effort levels. The last set of “good faith” criteria allowed institutions to interpret that they need take only the first step to be in compliance.
Provide Clear Guidance on Outstanding Authorization Issues, Especially the 50% Definition
If you wish institutions to comply quickly, detailed guidance will be essential, especially in the Department’s apparent expectation to assure compliance only if a student receives 50% of a program in another state. While every permutation cannot be anticipated, guidelines on what will be counted as “at a distance” would be helpful. This includes indications of how blended courses, internships, and joint degree programs would be counted.
It might be easier to forego the 50% definition and use each state’s criterion as the federal requirement. Otherwise, an institution might be obligated to be approved according to state regulations, but not for federal purposes. It is already difficult enough having more than fifty state definitions without also having to determine the a 50% level for each state, especially if the activity in the state might push an institution above or below that threshold from term-to-term. Having an authorization definition that differs from the states will be confusing to institutional personnel and students. It will also alienate those charged with enforcing state regulations.
Support the State Authorization Reciprocity Agreement
Beginning with the original guidance accompanying the issuance of § 600.9(c)[15] the Department has strongly supported reciprocity as a means towards compliance. Since that language (and the subsequent guidance) was vacated, the Department should restate its support for a reciprocal agreement. WCET strongly supports WICHE’s leadership in implementing the State Authorizaiton Reciprocity Agreement.
State Authorization for Foreign Locations of Institutions Located in a State
Other than appearing as part of the announcement for the new negotiated rulemaking effort, there has been little said about the concerns that the Department has about this issue. WCET was able to confirm that “foreign” refers to locations in other countries. WCET members have these questions:
Will any provision arising from this discussion apply to distance education in foreign locations?
Does this apply only to students who are eligible for federal financial aid?
In Conclusion
WCET has a long history of working on federal policy issues. Recently, we have also begun partnering with other educational technology and continuing education organizations in sharing policy perspectives. Some of the issues that arose from the original state authorization regulation had to do with those composing the regulation not fully comprehending the state of the art in distance education. WCET would be happy to serve as a resource and to work with its partner organizations (several of which are named in this document) in helping to craft forward-looking regulations.
Sincerely,
Russell Poulin
Deputy Director, Research & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu
303-541-0305
In honor of Memorial Day in the United States, our guest blogger is Gregory Barber who is retired from the U.S. Air Force. While learning online at the University of Maryland University College, he has lead in helping other veterans succeed in their studies. We thought you should hear his story…and thank members of the armed services and veterans.
For me, joining the military and eventually taking online classes were a means to an end.
My brother-in-law was a captain in the U.S. Air Force, and I talked with him about joining. He knew that I wanted to travel, get my education, and sharpen my skills in information management, so he showed me around the local Air Force base and discussed the advantages with me.
After retiring from the Air Force, Gregory Barber started a club to help other UMUC veterans
I decided to join, and apparently it was meant to be, because I stayed for 20 years. I retired with experience as a computer network defense operations manager, computer network defense network information analyst, information systems security officer, and network administrator.
Online education fit my needs, even if deployed
Online education fit with the life I chose. I had already taken some courses from community colleges near where I was stationed, and eventually I completed two associate’s degrees from the Community College of the Air Force.
I knew I wanted to continue my studies, and I researched several different institutions. I found that UMUC met my requirements—it was an accredited university, veteran friendly, offered easy access, and the tuition was affordable.
I decided to study online for two reasons. First, I wanted to try a different mode of instruction, and second, I was looking for a way to continue my education even if I was deployed.
The VeteransSuccess Club at UMUC
Based on my experience, I started the VeteransSuccess Club to offer UMUC students additional support services both online and face-to-face. The VeteransSuccess Club serves UMUC student veterans, active duty service-members, reservists, and their families. It is a relaxed environment where members can come and discuss their concerns, from military transition, employment opportunities, benefits, or to just have a conversation about what’s on their mind.
Along with many other student veterans here at UMUC, we created this club to provide support to the student veteran in overcoming those obstacles that might hinder their personal experience during their educational journey. We know that the club can be an essential component for student veterans at UMUC but we must have participation. Our desire is for more student veterans to get involved in the club and make their presence known.
Online learning gave me needed flexibility, but it’s not easier
To be honest, I thought online education would be easier than face-to-face instruction, and I thought the courses wouldn’t take much time to complete. I was wrong on both counts. For me, online courses were often more challenging than face-to-face, requiring that I arrange study time throughout the week in order to complete the required assignments.
Flexibility was by far the greatest advantage to studying online. I didn’t have to rearrange my schedule in order to make it to class; I could just go online whenever I had free time. A corresponding challenge, though, was that I was sometimes inclined to put off homework and wait to complete assignments until the last minute.
Group assignments could be challenging, as well, if a group member was tardy with his or her contributions. In a face-to-face classroom, you can just approach the person in class; online, you often have to resort to e-mail . . . then wait for a response.
I’ll never forget when, in an MBA courses, one student was assigned a segment of a project. The due date came and went without the student turning in the assignment or contacting other team members. As the project lead, I e-mailed the student repeatedly with no response. Ultimately, the instructor had to assist my team with a resolution.
Those challenges aside, there is no question that online education was an important factor in allowing me to earn both my bachelor’s and master’s degrees, offering access to the curriculum I needed when I simply wouldn’t have been able to attend those classes face-to-face.
Advice to someone starting to learn online
To someone who is beginning online studies, I always recommend starting one course at a time. That allows time to get comfortable with the learning management system, to get used to locating and communicating with professors and classmates in the online environment, and to get familiar with the requirements of the course and the professor’s expectations.
I’ll always remember the first online course that I enrolled in at UMUC. I logged in expecting to read a couple of articles, perhaps complete a one-page paper, and be done for the week. I was in for a rude awakening. Besides articles and several assigned chapters in the textbook, there were conference questions from the instructor and comments from classmates that I had to respond to, in addition to completing a two-page paper. I realized that this would not be the online course I anticipated.
Once you’re comfortable in the online environment, though, success comes down to time management. As an online student, it’s your responsibility to know when assignments are due; how to post comments, links, or documents in online discussions; and where to post them. Since most online students are adults with competing responsibilities, those are the sorts of obstacles that can become insurmountable if left until the last minute. Plan ahead and keep up with assignments, and you’ll do fine.
Thank you,
Gregory Barber
About Gregory Barber:
MILITARY BACKGROUND
Service Branch: United States Air Force
Years of Service: 20 years
AREAS OF RESPONSIBILITY
Information Systems Security Officer (ISSO)
Information Systems Security Engineer
Computer Network Defense (CND) Operations Manager
EDUCATION
Master of Science in Cybersecurity Policy, University of Maryland University College (UMUC), Adelphi, MD, Expected date of graduation: 4/14
Master of Business Administration (MBA), UMUC, Adelphi, MD, GPA 3.0, 08/2012
UMUC Certificate, Project Management for IT Professionals, UMUC, Adelphi, MD, 05/2008
Bachelor of Science, Information Systems Management, UMUC, Adelphi, MD, 12/2007
Associate of Applied Science, Information Management, Community College of the Air Force (CCAF), Maxwell AFB, AL, 05/2004
Associate of Applied Science, Information Systems Technology, CCAF, Maxwell AFB, AL, 05/1999
There Currently is No Federal Deadline for State Authorization for Distance Education I often get asked, “so what date is the new federal deadline for institutions to be in compliance with state authorization regulations?” The answer is that there is no deadline.
The Department of Education rolled back the clock on some state authorization rules.
After losing a court case and an appeal in federal court, the Department said last July that it will not enforce the vacated distance education regulation. Therefore, there is no federal deadline. Meanwhile, states expect that your institution comply with their regulations before you serve the first student in their jurisdiction.
So What State Authorization Deadline is the Department Delaying? The distance education portion of the regulation was § 600.9(c). There are two additional sections of the regulation (§ 600.9(a) and § 600.9(b)) that are not focused on distance education and remain in place. These sections focus on what the state must do to authorize an institution, including having third-party complaint processes, identifying authorized institutions by name, and other requirements.
The states were supposed to address the new federal requirements by July 1, 2011. Extensions were available to July 1 of this year. A ‘Dear Colleague’ letter in January of this year reminded states of the deadline.
Much confusion ensued and there was concern by those at all types of institutions that their students might suddenly become ineligible for aid over some technical requirements. Earlier this year, Dr. Sophia McArdle of the Department assured us that no student would lose aid because of this rule. I know that Sophia has been working hard to help states meet this year’s deadline, but there was just too much that had to be done. I applaud Sophia and the Department for keeping their word and for issuing a new ‘Dear Colleague’ letter that extends the deadline for states to have their rules comply to July 1, 2014.
While happy for the extension, I was disappointed by a couple missed opportunities:
Given the confusion on this issue, it was an opportunity to issue additional guidance. There was initial guidance give in October 2010 (see Federal Register page 66858) when the regulation was first issued in 2010, but apparently that was insufficient or people could not find it. I’m hoping that the extension gives the Department time to issue more advice on what states should do and how they know if they are okay.
The extension in the ‘Dear Colleague’ letter is actually issued to the institutions: “In order for an institution that cannot demonstrate it meets the State authorization requirements under the Department’s regulations to receive an extension until July 1, 2014, to implement §600.9(a) and (b), the institution must obtain from the State an explanation of how an additional one-year extension will permit the State to modify its procedures to comply with amended §600.9.” Legally, this might be the way it needs to be done, but the institution is only out-of-compliance due to state inaction. Therefore, institutions must check a list (that does not exist) to assure that their state’s authorization agency meets federal requirements (which are confusing and open to interpretation) to determine whether it should obtain a letter from that agency explaining why a delay was needed. Got it? Only a handful of states and agencies will be affected, but I wish I could give you a list which ones those are. It sure would have been nice to have an easier process.
What About State Authorization for Distance Education? The Department apparently took the first steps to reinstate the vacated distance education rule. In a Notice of Negotiated Rulemaking issued earlier this year, they are seeking comments on this issue. You may recall that the original rule was vacated because they did not properly follow the commenting requirements. Now they are.
I will be at the Hearing on this Negotiated Rulemaking that will be held in San Francisco on May 30. I’ll let you know if anything interesting happens. Let me know if you will be there.
Russ
Russell Poulin
Deputy Director, Research & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu
WCET welcomes Lauren McLarney of the National Federation of the Blind in giving us some recent history of and the next steps for proposed regulations regarding accessibility to educational technologies for those with disabilities. Thank you Lauren.
I was in college a mere five years ago, but in that short period of time things have really changed. The integration of technology into the educational sphere has fundamentally altered the teaching and learning process, and those changes – the arrival of digital instructional materials and the speed at which innovators come up with new and revolutionary things – are mostly for the good.
Technology has increased the accessibility divide
Before these changes, blind and other print-disabled students faced barriers to education and were segregated from mainstream students. But now, curricular content that was once available only in textbooks and during lectures can be disseminated through electronic books, web content, digital library databases, advance software, and mobile applications. Compared to the print world, which excluded the print-disabled because it is inherently inaccessible, this intersection of technology and education creates opportunity to expand the circle of participation and allow universal access to mainstream products for all students, disabled or not.
Instead, inaccessible technology has permeated the classroom causing print-disabled students to be segregated more so than ever before. Rather than level the playing field, technology has created a whole slew of challenges to replace the traditional barriers to education faced by print disabled students. What went wrong?
Commission reviews “accessible instructional materials” and makes recommendations
In 2008, the Higher Education Opportunity Act created the Advisory Committee on Accessible Instructional Materials in Postsecondary Education for Students with Disabilities (AIM Commission) to find out. The AIM Commission was charged with talking to postsecondary students, university personnel, parents, and industry experts. They looked at the status of accessible educational technology in postsecondary education, the reasons manufacturers have failed to embrace accessibility solutions for their products, and what institutions are doing to minimize the impact on print disabled students.
In June 2010, while the AIM Commission was doing its research, the Department of Justice (DOJ) and Department of Education (DOE) jointly issued a “Dear Colleague” letter reminding K-12 and postsecondary schools that deploying inaccessible technology was a violation of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. In late 2011, the AIM Commission released its findings: “students with disabilities have experienced a variety of challenges, including blocked access to educational opportunities and matriculation failure resulting from inaccessible learning materials and/or their delivery systems,” and “…while there are a variety of emerging improved practices in the area of AIM, there is still persistent unmet need.” The AIM Commission made eighteen recommendations (see EDUCAUSE summary) for fixing this – some calling for legislation, some targeting industry, and some directed at the DOE.
After years of inaction, action is required
Fast forward to 2013. Not a single recommendation has been implemented.
That is two years since the report’s publication and five years since Congress first noticed a problem. Five years of minimal progress. Five years of disabled students being further segregated and challenged to finish their education without equal access. In the interim, DOJ and DOE attempts at enforcement have failed to solve the problem. Schools continue to embrace inaccessible technology at ever-growing speed. When will schools stop retrofitting inaccessible products and start demanding full accessibility from the start?
The Technology, Education and Accessibility in College and Higher Education (TEACH) Act is our solution. It calls on the Access Board to develop accessibility standards for electronic instructional materials and their delivery systems used in postsecondary education. The DOJ will then issue regulations based on those standards, and enforce them as requirements under the ADA. The standards will also apply to agencies of the Federal government under Section 508 of the Rehabilitation Act, should those agencies choose to purchase instructional materials.
TEACH is based on the first recommendation of the AIM Commission report, which calls on the Access Board to develop accessibility guidelines for instructional materials used in postsecondary education. Second, TEACH does not create new liability for postsecondary institutions. Rather, it provides clarity to the pre-existing mandate of equal access, which is already required under ADA and enforced by DOJ and DOE (as stated in the Dear Colleague).
If TEACH becomes law, all pre-existing flexibilities, statutory provisions, and implementing regulations under the ADA would still apply. This means no new private right of action, no new penalties, and no new exemptions. TEACH simply provides focus to a pre-existing legal obligation. The objective of TEACH is to significantly increase the amount of accessible instructional materials in the marketplace and in the classroom without creating any new liabilities that are unfamiliar to postsecondary institutions or would inhibit innovation.
Help us in supporting students through the TEACH Act
Most postsecondary institutions want to provide their disabled students with equal access, but they aren’t sure what accessibility looks like and they claim there are not enough affordable options in the marketplace. Manufacturers say they are willing to embrace accessibility solutions, but they do not see a large demand for it. Institutions are blaming manufacturers; manufacturers are blaming institutions.
In the end, the burden falls on the student.
It has been that way for more than five years – it is time we take action. The AIM Commission report gave us the data to know where to start, and the ADA provides the legal framework to get this done without reinventing the wheel. TEACH will make it happen.
If your entity (institution, state agency, organization, corporation, etc.) would like to add your name to the growing list of those endorsing the TEACH Act, please contact me. Once the bill is introduced, contact your U.S. Senator or Congressperson to obtain their support. Meanwhile, take action on your own by making sure your technologies are accessible without waiting for TEACH.
Will you support this initiative – or will we ask disabled students to wait another five years?
Lauren McLarney
Government Affairs Specialist
National Federation of the Blind
LMcLarney@nfb.org
Just days before Halloween in 2012, the residents of New Jersey faced the high winds, storm surge, and flooding from Hurricane Sandy. We asked Sheri Prupis from NJEDge to give us an update on how New Jersey’s colleges and universities weathered the storm. She also provides lessons learned for those of us who were lucky this time, but need to be prepared for the next emergency.
My days, like most of us, are filled with technology-related activities. I am the Vice President for Academic and Community Engagement for New Jersey’s State Research & Education Network, NJEDge.Net. Every day I am up to my eyeballs in networking, academic technologies, virtualization, consortium activities, and more. Even on days when I am away, I check in several times to look at the status of my projects. I believe in the work that my colleagues and I do, and I wouldn’t have it any other way.
In the aftermath of Hurricane Sandy, Richard Stockton College College helped by holding a food and clothing drive.
But who would have imagined that six months ago, on October 29, 2012 at 8:30pm, all of it would come to a screeching halt in New Jersey. Hurricane Sandy hit and hit hard. All our priorities changed.
We knew for a week that the hurricane was coming. NJEDge members (higher education institutes, K-12, research organizations) began to prepare.
Colleges and universities sent students home, closed their campuses, brought in extra fuel, and
worked with faculty on learning continuity strategies; all of this to keep learning, teaching, and research going, even if not on campus.
New Jersey was hit hard by Hurricane Sandy. We sustained economic losses up to $300 billion. Our higher education community by the shore was hit the hardest, but practically each institution had some malfunction. Luckily for them it was not the NJEDge support system.
With NJEDge’s shared services, cloud services and remote hosting, most members kept their local networks up and their LMS’s running. NJEDge’s statewide network, which provides Internet and Internet2 performed as designed and never went down. We remain robust. We never lost connectivity, because redundancy was built in. Internet access was not a problem, but power and communications on each campus was severely tested.
Lessons Learned
Several lessons were learned for the NJ Higher Education NJEDge.Net members.
Redundancy, Redundancy, Redundancy Redundancy is not limited to networking:
Application servers, authentication services, and web services need to be available in more than one location.
Fuel resources have to be available from multiple vendors.
Staff must be able to work in multiple modes. Institutions must pay for air cards in mobile devices so that staff can perform vital tasks.
Instruction must be available in multiple media (text, DVD, Internet, face-to-face).
Don’t Forget the People
Most important was the lesson to not forget people and their struggles: so many of our members invited their local communities in as soon as the institution regained power. Nearly half of the members made accommodations regarding exams, scheduling, and due dates – and still managed to end the semester on time.
Having the network running, having the LMS available simply isn’t enough. Our faculty, staff, and students were worried about parents, children, and spouses. They were looking for power, food, and places to live. A few of them are still in temporary housing. What was amazing was realizing that we had, at each of our institutions, a working community. Using social media, our staff, faculty, and students were able to share information and resources and help one another.
The single most important role that NJEDge and our members had was providing a communications channel between individuals looking for resources of all kinds.
Next Steps Social media was used at many New Jersey institutions to keep students informed of the situation on their campus. While electricity was out and schools closed for days, smart phones kept communication afloat.
It is heartening to learn that faculty and students from many schools pitched in helping residents find temporary housing and to provide provisions and clothing. Many of the residents along the shore lost everything. Several schools created fund drives to help the victims of the storm and many used social media to get the word out and even to solicit contributions.
While we hope never to experience another hurricane as damaging as Sandy, we need to set up contingency measures. New Jersey state agencies, research and hospital institutions, and the higher education community, along with K-12 districts represent a sizeable population to protect. We welcome any examples of helpful technology protection colleagues can offer.
Sharing Our Stories
This blog posting is created so that we can share stories within the community, and derive contingency measures that can be put in place for the next super storm.
We reached out to our members asking for their experiences. What follows are their stories.
Brookdale Community College
NJEDge and Brookdale Community College were in frequent contact working to keep mission-critical services up during the storm and its aftermath. In particular, Brookdale’s website was all-important conduit between college officials and our students, faculty, and staff. Through the website we were disseminating information about when each campus would re-open and providing information about help and resources to members of the campus community affected by the storm. It was imperative that it remain available.
Our first call to NJEDge was Monday night at 11:30 PM during the worst part of the storm. All of us were at home without electricity when we received notice from our monitoring service that the college website was down. As damaging winds battered our homes, an NJEDge employee came to our aid to help orchestrate the changes needed to switch our website to Brookdale’s cloud-based backup site in Chicago.
The next day, the Office of Information Technology staff drove around downed trees and dangling power lines to arrive on campus, at which time we were able to find and correct a minor problem with our generator. As soon as we had brought our Lincroft data center back online, NJEDge assisted with DNS changes needed to restore service. Unfortunately, our return to the Internet was short lived, as twelve hours later our generator failed again, this time burning up an electrical part that was on backorder and unavailable anywhere in the country. Again, NJEDge quickly, and cheerfully, orchestrated the communication with Cogent which was needed to bring up our emergency site.
Although everyone was frustrated by the slow pace of electrical service restoration, many of in the college community remarked that they were pleased that Brookdale’s emergency website was available and up-to-date.
Fairleigh Dickinson University Fairleigh Dickinson University (FDU) included in its preparation for Hurricane Sandy the rental of four large diesel generators and three 7,500 gallon trucks with diesel fuel to service the Student and Recreation Centers on each campus. These generators were in addition to the permanently installed units that service the data centers and other select building life safety systems. However, Hurricane Sandy prevented the normal delivery from FDU’s supplier as the supplier was flooded from the storm. The University opted to not utilize the prearranged fuel as it had potentially been contaminated by brackish water during the flood. In order to keep operations on keel, FDU arranged for local diesel suppliers to purchase out-of-state fuel.
The out-of-state supply was not ample to service the generator need. As the Metropolitan Campus burns low sulfur diesel fuel in lieu of #2 fuel oil in its oil boilers, for emissions compliance, approximately 15,000 gallons was redeployed from the 20,000 gallon tank from one of the lecture halls to the generators on both campuses.
The College at Florham campus was out of power for nine days and the Metropolitan campus for seven days. This was further complicated by students opting to stay on-campus instead of returning home.
FDU was well prepared for the storm and kept strategic buildings and services open with the generators and creative fueling. What we learned from the experience is to have multiple fuel sources with multiple depot availability.
Richard Stockton University of New Jersey Stockton was closed Sunday-to-Tuesday during Super Storm Sandy. Monday was an instructional day. Tuesday was an advising day. Faculty had to make alternative plans for contacting their students. Some used telephone, email, Wimba Classroom, or set up appointments later in the week.
Approximately 200 students and employees were hard hit by the storm, many losing their homes. Assistance funds were set up with students and employees being very generous in their contributions.
From a technology standpoint, our data center is equipped with a UPS (uninterupted power supply) and generator. Even though the campus lost power our systems remained up throughout the storm. Power outages in the region were localized. Those who were not affected by the storm surge and power outages were able to continue with online work as usual. Student and faculty with the Blackboard Mobile Learn app were able to access the learning management system using smart phones and tablets.
Richard Stockton maintained some measures at working “against the tide.”
Sending the residential students home was a good idea and helped ease the burden of feeding and housing the small number remaining. Had we not sent the students home, it would have been necessary to feed 2,800 students for the duration of the storm.
Since the storm Physical Plant has purchased 150 cots in the event a situation like this occurs again. This will alleviate the need for personnel to move mattresses to the Campus Center, which became very labor intensive.
The need for additional emergency generator power became evident. Although power was lost only for a short period of time, any longer would have become problematic. The President has asked Administration and Finance to submit additional generator information and cost to him for consideration.
Georgian Court University
Classes were cancelled as soon as news of the magnitude of the storm was forecasted. Georgian Court (GCU) shut down its homepage, activated campus security by mass notification to students through all the emergency methods by texting, using the university’s Facebook and Twitter accounts as communication center.
When the campus lost power, our core system went down. Bringing it back up took a few hours, and this happened twice in the days immediately after Hurricane Sandy. Each time it went down, it took time to bring the servers back up in the right sequence, thus affecting a number of operations (e-mail, campus Internet access, ANGEL, the GCU portal). After the second loss of power, the university turned to its portable generators to power the bunker where our servers are kept.
For the IT staff, it was also difficult to determine how well our communications were getting through to members of the campus community. We didn’t know what other systems (home phones, e-mail, cell phones) were available to our faculty, staff, and students.
With the hurricane directly overhead, the GCU campus lost power. After four days of continual operation the Data Center generator ran out of Diesel fuel. That’s when the real IT work began. Once fuel arrived, the staff were tasked with bringing all services back up ASAP, which took over 6 hours. The next hurdle came three days later (one full week with no power to campus) when the generator started to spit and sputter requiring immediate maintenance. Luckily the IT staff had enough time to shut all the servers down properly. Shortly after shutdown, the “all clear” was given and the IT staff began the startup ritual for bringing services online. This time only the essential servers and services were brought up. These included Active Directory, Exchange, and SharePoint, each to support communications of staff, faculty, and students. Crucial data systems such as the File servers and ERP system were left in the safer off-state site until campus power was fully restored a few days later.
We saw definite benefits during the outage by having our main web site and student LMS hosted off-campus. For those that remained on-campus during the storm, they were challenged with outages to the IP surveillance system, the IP-based building card access system, and our small deployment of VOIP sets. It came down to power, whereas the GCU buildings with generators and utility power (there were a couple) had network connectivity, wireless, and telecommunications.
William Paterson University William Patterson University survived the storm well. The damage was mostly from fallen trees. The University had well-defined disaster plans and a standing committee, which immediately went into action.
From a technical standpoint, the WPU Data Center ran on the natural gas generator power so all computer and network systems remained operational. One of our Internet circuits went down for a few hours affecting external telephone services to campus, but all Internet traffic routed to a secondary circuit did not lose data connectivity. We had a minor disruption of on-campus telephone service because an older generator supporting the telephone equipment did not start-up automatically when the power failed. Cell service was acceptable and campus radio communications were not disrupted, so there were no serious communication problems as a result of the loss of telephone service.
Our alert system, ConnectEd worked fine. as well as our web site postings and WPU e-mail announcements. Not all network switches and routers are on generators, so in those buildings, access to the campus network was unavailable until power was restored. We have plans to have all network equipment on generators and move to complete VoIP which would provide better communications resiliency.
New Jersey Institute of Technology
In the final days of October, it became clear that the NJIT campus in Newark was in the path of Hurricane Sandy. For the IT team at NJIT, preparing for one of the most disruptive storms in recent history meant being ready for a loss of network connectivity, a prolonged power outage that could last days and even possible water damage to their data center environment. They decided that it was necessary to take proactive measures to ensure the availability of critical IT services. Deemed the most important piece to protect was the university’s web presence.
“The NJIT website is the face of the university and all of its college websites,” explained Kevin Byron, director of core systems for NJIT. “It is the primary communication tool among all members of the NJIT community. To have the website up [during a natural disaster like Sandy] was critical.”
The NJIT team decided that the best way to ensure the availability of the university’s website was to relocate their web presence. They sought a solution they could implement quickly with the storm approaching. They needed to act. And they needed to act soon.
Byron and his colleague, Matt Hoskins, senior enterprise architect for NJIT, reached out to NJEDge.Net, the statewide, member-focused provider of network and related services and a trusted strategic partner to the higher education community in New Jersey.
Critical Communication On Monday, October 29, as Sandy reached the coast of New Jersey and moved inland, New Jersey Institute of Technology was prepared. Even with a loss of power in the NJIT data center environment, there was no lag, no dead air on their website. And they were able to maintain their web presence throughout the duration of the storm and its aftermath. This proved to make all the difference for NJIT students, faculty, and staff.
The NJIT campus lost power for approximately 22½ hours, beginning Monday night and continuing into Tuesday evening. And while power was restored, Newark and its surrounding areas were in such disarray from the storm that classes were cancelled for five days and the campus was closed until the morning of Saturday, November 3.
During the storm, NJIT staff were able to communicate campus-wide status updates via a text ribbon at the top of the NJIT webpage. These updates included class cancellations as well as services availability and restorations.
“That text ribbon had a 200 character maximum, but during the storm those were the most important 200 characters on the entire site,” Byron said.
The updates included a link to the NJIT SOS Blog, which contained more detail than could be communicated effectively through the text ribbon. NJIT SOS is a WordPress blog, so the infrastructure was logically distinct from the NJIT campus and available.
In the days following the power outage on campus, the number of hits on the NJIT SOS Blog skyrocketed. The ribbon and NJIT webpage were clearly important to a great number of people. Byron and Hoskins observed that most users who accessed the blog and website during the storm did so using smartphones.
A Sound Solution
On Friday, November 2, pleased with the restoration on campus, the NJIT website was returned to its primary location on the NJIT campus datacenter environment in Newark. All agreed that it was a successful undertaking and were pleased with the ease with which it was accomplished.
New Jersey Homeland Security NJEDge played a part in keeping communication fluid between the Office of the Governor with national and state officials throughout Hurricane Sandy. Through our virtual colocation and redundancy abilities, we were able to provide Vidyo videoconferencing telepresence to the different departments– the Office of Homeland Security and Preparedness, the New Jersey State Police, Regional Operations Intelligence Center, Office of Emergency Management and the National Guard – to be informed in real time.
We welcome any examples of ways to protect students, faculty, staff, and technology that colleagues can offer.
Sheri
Sheri Prupis
Vice President for Community and Academic Initiatives
NJEDge.Net Sheri.Prupis@NJEDGE.NET
In mid-April of this year, the U.S. Department of Education announced an “intention to establish a negotiated rulemaking committee to prepare proposed regulations for the Federal Student Aid programs…” Through this process, the Department is visiting or revisiting several issues that are near and dear to the hearts of those of us in the distance education community: financial aid fraud and state authorization.
It is also taking input on other issues, including: cash management of federal financial aid funds, state authorization for foreign locations of institutions located in a state, clock-to-credit hour conversion, gainful employment, and changes from the Violence Against Women Reauthorization Act of 2013.
This is the beginning of the process for the Department creating new regulations on these issues. It is important that our voices be heard at the outset. We wish to help inform and guide these discussions to dispel some of the misconceptions upon which some regulations were based in the past.
Seeking your input
By giving our feedback now, let’s hope to avoid some of the confusion from previous regulations.
On behalf of WCET and the WCET State Authorization Network, we will be submitting comments on the following issues. I’d love your help, feedback, and suggestions on what should be recommended:
Financial aid fraud
The Department references a previous call for negotiated rulemaking that was issued in May 2012 that had a primary focus on the fraudulent use of financial aid funds. While fraud comes in many forms, there is distrust of distance education and great worry about the opportunity for the misuse of funds for students who don’t appear on campus. Such concerns led to the proposal in last year’s federal budget from the Administration to lessen Pell eligibility for distance students. While that proposal did not go forward, it is probably still on their list of possible solutions.
Briefly, here are some points that we would like to make in comments:
Don’t confuse fraud (someone faking their identity purely to get money) with academic integrity (a known student cheating on a test to get a better grade).
Don’t punish the innocent. The Pell grant proposal was an example of a solution that would be equal to solving the problem of bank robberies by closing all the banks.
Promote education of the types of suspicious activities that are common among fraudsters. Sometimes faculty or other administrators can raise red flags that others would not see.
Promote good practices in combating fraud, both in the administrative and academic sectors of the institution. The more difficult it is for the fraudster to jump through administrative and academic hoops, the less inclined they are to commit fraud.
Don’t look for a silver bullet. It’s not there.
What else would you suggest?
State authorization for distance education
The regulation issued in 2010 was vacated by the federal courts ruling that the proper rulemaking process was not followed. This is the first step in their following the rulemaking process and my guess is that this regulation is on its way back. I’m NOT going to recommend that the federal government stay out of this issue because it is with us regardless of what they do. Some comments that I would like to make:
If you reissue this regulation, be sure that there is adequate time for institutions to comply and for states to respond. Even though institutions have been repeatedly warned about this issue, a large number are still out-of-compliance.
Repeat the Department’s strong support for reciprocity. In the past, the Department has supported the notion of reciprocity several times, but some people still can’t hear it and previous support was based on the vacated regulation.
Please provide clear guidance on several issues that remained unclear from the previous round with state authorization, such as:
how you will count if a student can receive 50% of a program in another state,
will consortia agreements suffice for reciprocity,
how do internships (and other experiential learning) fit into the authorization requirement,
will the current worries about “exemptions” for in-state institutions also apply to providers from other states, and
what is the penalty for non-compliance?
Some of these really get into the minutiae and I will expand in the final comments.
As much as possible, rely on each state’s definition for authorization and don’t create new definitions to layer on top of those regulations. For example, differences in regulations could lead an institution to being in compliance for federal purposes but not for state purposes.
What would you add?
State authorization for foreign locations of institutions located in a state
This one really surprised me and it is worded oddly. I’ve confirmed that by “foreign” they are talking about institutions that have locations in other countries. With the growth of such institutional ventures abroad, I can see that the federal government might be concerned about the quality control. I’ve also learned that there are some institutions that are located in the U.S., but teach no students here. They look like a U.S. institution, but no U.S. entity has approved them. There’s great potential for defrauding foreign students. I’m not sure how this fits in with federal financial aid, but we’ll learn more about it. My comments:
Does this apply to distance education, as well as “locations?” If so, what does that mean?
Is this only for federal financial aid?
What are your thoughts?
Overall philosophy
I have one overall philosophy that I wish that regulators move toward adopting:
Regulations should not differentiate by mode of instruction unless the regulations are actually about the tools used in the mode of instruction.
Let’s stop differentiating aid based upon whether a student is on-campus or not. We should focus on student outcomes. Our future will see more technologies, more modes of instruction, greater mixes of face-to-face and distance, and a greater focus on competency-based instruction. It is getting harder and harder to differentiate this modes of instruction as they all become intermingled, thus making the differentiation obsolete.
Stop worrying about the inputs. The current definition of distance education includes many technologies. Given the rapid change in technologies, any such list is out-of-date as soon as it is published.
Regulations should be in place when they are actually about the tools being used. Institutions have been lax in assuring accessibility for the disabled. It makes sense to assure that access is open to all.
Next Steps
Comments are due to the Department by the end of May. You may submit your own comments. To be contribute to WCET’s official response, supply comments below or send your thoughts directly to me at rpoulin@wiche.edu by Monday May 20. There are also three opportunities to testify on these issues. The dates and process to register to testify is in the announcement.
This feedback process is just the first step. Later this year the will ask for nominees to be on a Negotiated Rulemaking Committee to consider specific regulatory language. We will continue to follow these issues, actively participate, seek you input, provide comments, and suggest stronger action, if needed.
Your input makes our collective voice stronger, so thank you for sharing it!
Russ
Russell Poulin
Deputy Director
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu
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