Author: Russ Poulin

State Approval Regulations: Update on Conversations and Activities

By Russ Poulin

December 21, 2010

5 Comments

Okay, I have to confess that I created the title for the December 7 webcast “Clarifying New Federal Regulations on State Approval for Distance Education.” I really appreciated the willingness of Fred Sellers from the U.S. Department of Education (USDOE) in interpreting the new “State Approval” regulations for us. While we learned much, the number of calls I’ve had on this issue since the event tells me that perfect “clarity” was not achieved. Okay, so I reached high with that title.

As a result of these conversations, I’ve created a web page that includes a link to the webcast archive and basic information about this issue. I will continue to update the page, as I learn more.

Below are highlights from conversations with Fred Sellers, representatives from other organizations, and other interested folks. These items highlight activities that are in-the-works, planned, or just-plain-old-ideas:

Clarifying Letter. The USDOE is working on a letter addressing some (but probably not all) of the issues that are still requiring clarification. This letter will cover the “State Approval” issue and other regulations released in late October. Expect the letter to be released in January.
Chronicle of Higher Education Article. I had an extensive conversation and several e-mails with Kelly Field who wrote “State-Oversight Rule Draws Protest from Colleges and Congress.” The article gives a good overview of the issue.
Congressional Intervention? Given comments by Senator Enzi in the Chronicle article and Senator Harkin on the Senate floor, there is some belief that legislation might be introduced on this issue. What the legislation would do is up for question. I’ve had initial conversations with the organizations in the next bullet and Bruce Chaloux from Sloan-C’s board about our organizations working together on taking a position on this issue. If you have more information on any legislation in the works, let me know.
Rules Vary by State. We had several questions about the particulars of receiving state approval, such as: Is approval by institution or program? What constitutes ‘operating’ or ‘physical presence’ in a state? Do I have to renew every year? How does accreditation factor in? The answer to this, and many similar questions, is that it depends on the rules of each state. For your institution, you need to learn what the rules are in each state.
THE List. There were several questions during the webcast asking where to find a list of state approval agencies. I have had many conversations on this issue. While some efforts are in the works, I worried that they would not produce results until late Spring. The Southern Regional Education Board, the American Distance Education Consortium, and the University of Wyoming are assisting in creating a basic state-by-state list. While this list won’t provide complete information on this issue, we are hoping to provide enough information by the end of January for distance education institutions to begin tackling this issue. I’ve also heard from my friends in the State Higher Education Executive Officers that the USDOE may be reconsidering its decision NOT to make a list. That’s good news. Also, watch for an offer from the Dow Lohnes law firm for a discount to WCET members on their updated report regarding approval regulations for each state.
Creating a Model Interstate Compact. In case you missed it, the Presidents Forum of Excelsior College and the Council of State Governments recently announced a two-year grant from Lumina Foundation for Education. From the announcement, they will : “develop a model interstate compact that provides a basis for more rational and efficient state approval of online programs, protects consumers and addresses barriers to student success. A common set of rigorous standards also would support the national agenda calling for increased degree completion among adults.” Paul Shiffman of Excelsior College has agreed to write a blog post about their plans.
Twitter Hasthag. Thank you to Ellen Marie Murphy of Plymouth State University for asking about a hashtag to help you follow this issue on Twitter. We agreed to use #stateapp.

That’s enough for now. I’ll continue to update you on what we are doing and what I’ve learned. Let me know if you know of other efforts that should be reported.

Wishing you happy holidays and a fruitful new year.

Russ Poulin
Deputy Director, Research & Analysis
WCET
rpoulin@wiche.edu

Legislation, Regulation, State Authorization, U.S. Department of Education

Practice

Challenges and a Solution for Training New Online Adjunct Faculty

By Russ Poulin

December 13, 2010

Watch for more information about the regulations regarding state approval of distance education coming soon. Meanwhile, I am pleased to introduce this guest posting about developing online adjunct faculty.

Faculty development for distance teachers has long been thought to be a key factor in ensuring the quality of instruction. For those new to any activity, having a little help on how to improve performance seems like a good idea. However, results from the recently released “Managing Online Education” survey conducted by WCET and the Campus Computing Project, found that only 51% of those institutions responding had mandatory technology training for those teaching in online programs. Of course, institutions without mandatory development often have successful voluntary programs.

To address the special problem of preparing adjunct faculty for online instruction, I’d like to turn the rest of this post to Bobbi Dubins from WCET-member MarylandOnline. Famous for developing Quality Matters®, MarylandOnline is a consortium of higher education institutions in Maryland dedicated to advancing distance education and enhancing the availability and quality of e-learning.

Photo of Bobbi Dubins — Bobbi Dubins, MarylandOnline

Thank you for the gracious introduction and for the opportunity to share this information with your readers. MarylandOnline sought to meet the needs of its member institutions, many of whom had difficulty in finding qualified adjunct faculty to teach an increasing number of online courses.. While training for all online faculty is important, adjunct instructors present specific challenges in that they often find it difficult to attend face-to-face or daytime professional development sessions. In addition, a survey of 37 Maryland institutions indicated that a number of institutions found it problematic to provide faculty training, citing lack of staff and lack of time as primary obstacles. This is a challenge for many institutions across the nation, as they see budget cuts and, at the same time, an increase of adjunct faculty members. Utilization of a fully online course offered through MOL was seen as one way to address these challenges.

MarlylandOnline’s response to these needs was to create the Certificate for Online Adjunct Teaching (COAT) as an online professional development course for higher education adjunct instructors who are interested in learning how to teach online. Work on the COAT course began in 2009-2010, using research to guide the development. The COAT program is somewhat unique in that it takes an inter-institutional approach. Research was conducted, and the course was developed, by a group of experienced faculty members and instructional designers from a number of Maryland institutions working collaboratively. The course was, of course, designed using the QualityMatters® standards. The course was piloted in April 2010, with 18 adjunct instructors from 10 Maryland institutions participating and providing extensive feedback.

Course objectives include eight topic areas that were identified as core competency areas for online instructors: orienting students, basic instructional design principles as applied to the facilitation of online courses, technical skills, Learning Management System (LMS) skills, pedagogy, social processes and presence, facilitating online discussion and collaboration, assessment, and legal issues (ADA, FERPA and copyright).

Key features of the course are instructor modeling of online teaching best practices, extensive student-student interaction (i.e. community building and collaboration), and an emphasis on pedagogy and social processes and presence. Participants spend about 5 hours per week on course activities, which results in total approximate training time of 45 hours over the nine week period. Of particular note is the importance of instructors experiencing online learning from the students’ perspective, which many participants indicated was especially enlightening. Formally launched in September 2010. Registration is open to any adjunct faculty, regardless of institutional or state affiliation

Thank you, again, for the opportunity to share information about this new program. We plan to continue conducting research and gathering feedback from instructors and institutions utilizing the program in order to keep the course current. For more information about the MarylandOnline Certificate for Online Adjunct Teaching (COAT) program, please see http://www.marylandonline.org/coat.

Bobbi Dubins can be reached at: bdubins@allegany.edu.

Faculty, Instructional Design

Uncategorized

What Do We Know about State Approval of Distance Ed?

By Russ Poulin

December 2, 2010

7 Comments

The U.S. Department of Education recently released new regulations regarding the state approval of out-of-state institutions operating in each state. These regulations put some expectations both on states in regulating those out-of-state institutions and the institutions in meeting the regulations of each state in which it “operates.”

As representatives from the U.S. Department of Education observe, most of this is actually NOT NEW. There has always been an expectation that institutions follow the state laws in which they operate. What is new is that the U.S. Department of Education is putting institutions on notice that they could be asked for proof of being approved to operate in specific states. Failure to provide the proof to operate in a state will put the federal financial aid eligibility of students residing in that state in jeopardy.

Several signs with parking regulations on the same poll. — Interpreting regulations is not always easy.

While this might not be new, the letter of the law has not been followed completely either by states or institutions.

So, what do we know about the current state of this state regulatory process? What is the impact on state regulators and what is the impact on institutions? What does it mean to “operate” in a state? Three surveys give us a clue.

Impact on State Regulators

Earlier this year, the Western Association of Schools and Colleges (WASC), a regional accrediting agency, sought the advice of the Kessenick, Gamma, and Free law firm about the state approval regulations while they were still being considered. They evaluated the impact on the state licensure schemes in each of the fifty states. Please note that this survey was performed on the proposed regulations, but most of the provisions survived to the final regulations that were recently published.

What did they find?

“The results of the State-by-State analysis are as follows:

the laws of twelve (12) States will, in our opinion, comply with the Proposed Regulation;
the laws of six (6) States will, in our opinion, clearly not comply with the Proposed Regulation;
the laws of thirty two (32) States will probably not comply with the Proposed Regulation (i.e., it is doubtful that the laws of these States will comply with one or more of the four criteria).”

Again these are results of a survey conducted before the regulations were made final, but it seems apparent that significant work will be needed in many states. See the full report to determine how your favorite states fared. Thank you to Barbara Beno of WASC for sharing this information with us.

A new report released earlier this week by the Council for Higher Education Accreditation provides some assistance on these issues. “State Uses of Accreditation: Results of a Fifty-State Inventory” provides an updated look state approval processes, but, understandably, does so from the accrediting agencies point-of-view. The report is helpful in updating state requirements and the list of licensure/approval agencies for each state.

While states can address these regulations individually, another option is for the creation of reciprocal agreements among states to ease the approval process. For example, the Southern Regional Education Board’s Academic Common Market/Electronic Campus might provide some relief for Southern states. Conversations about how to create more interstate compacts have just begun and WCET is participating in these discussions or trying to follow them.

Impact on Institutions

Each state uses its own laws to determine whether an institution is legally operating within a state. In the 2006 survey “A Survey and Report on the Bases for the Assertion of State Authority to Regulate Distance Education” by the Dow Lohnes law firm, they asked several questions about which activities would trigger each state’s licensure laws. Thank you to Mike Goldstein and Ken Salomon for sharing this report with us.

As can be seen by the following results, the regulations and notion of ‘physical presence’ across the states is quite variable. Again, these results are old, but contain the best evidence on this issue that I have seen to date.

“Would enrolling state residents in a strictly online class, considered alone, constitute a presence sufficient to require some type of licensure?” To this questions, 23% of the states said that this would be enough to exercise jurisdiction.
“Assuming an intent to enroll students from the state, would television, radio or print advertising in local medias, considered alone, constitute a presence sufficient to require some type of licensure?” To this question, 51% of the states said that this would be enough to exercise jurisdiction.
“Assuming an intent to enroll students from the state, would requiring students to take examinations at a location within the state, considered alone, constitute a presence sufficient to require some type of licensure?” To this question, 80% of the states said this would be enough to exercise jurisdiction. This could be a problem for some distance courses that use local proctors to administer tests.
“Assuming an intent to enroll students from the state, would participating in college fairs, considered alone, constitute a presence sufficient to require some type of licensure?” To this question, 33% of the states said that this would be enough to exercise jurisdiction. This is my favorite result. It has nothing to do with distance education, but do you really think any state is checking on which institutions participate in college fairs?

So, What Should We Do?

First, we will learn many more details in the December 7 free WCET webcast: “Clarifying Federal Regulations on State Approval for Distance Education.” Fred Sellers, U.S. Department of Education, wrote the new regulations. He will us understand what is intended and will answer questions.

Next, I think that the states (both individually and in partnerships) will need to figure out how they will address the regulations. Different groups are having discussions on this including The State Higher Education Executive Officers, The Presidents’ Forum of Excelsior College, SREB, and WICHE. As plans get more concrete (or even less murky), I’ll let you know.

Meanwhile, institutions should be reviewing where they are enrolling students who obtain financial aid and what state approvals they may currently have in pocket.

Finally, while these regulations go into effect June 30, 2011, we should be glad that there are opportunities for institutions to request extensions to this deadline in states where authorization cannot be granted on time. I think we’ll be using those extensions.

Photo credit: Some rights reserved by Dave Kliman

Reciprocity, Regulation, State Authorization, U.S. Department of Education

Uncategorized

Will Distance Ed Plans from California’s Legislators Have Broader Impact?

By Russ Poulin

November 4, 2010

2 Comments

Containing about 12% of the population of the United States, one can’t help but feel that when California sneezes, the rest of us might catch a cold. That’s one reason we should pay attention when some big distance education strategy initiatives are being considered by the state’s legislators.

Last week, California’s Legislative Analyst’s Office released the report: “The Master Plan at 50: Using Distance Education to Increase College Access and Efficiency.” It received some national press, but I’ll be curious to learn more from our California friends when WCET’s Annual Conference travels to La Jolla next week.

In a state where distance education programs have been highly distributed, the report recommends “that it is both appropriate and desirable for the Legislature to provide more guidance on a statewide vision for distance education, including expectations concerning the segments’ use of public resources for the program.”

Beach chair, laptop, and sunglasses — Preparing for the WCET Annual Conference in La Jolla

I provided insight earlier this year to a California legislative analyst on several issues in the report, so I was interested in the outcomes. I gave them the contacts for the collaboration section of the report and was glad to see that they interviewed those people. Following are the seven recommendations and my comments on each one.

1) Distance Education Definition: Adopt a standard definition of distance education for segmental reporting purposes.

Within a few weeks this year, I was contacted by California, Kansas, and Minnesota about the definition of distance education. It’s been a surprisingly big issue this year. California’s community colleges classify a course as “distance” if more than 50% of the instruction is at a distance. Having a standard definition for all of California’s higher education sectors would allow the Legislature to measure workload and track enrollment trends. The report recommends using the 50% definition. As other states are fishing for definitions, a decision by California can have a larger impact.

2) Report on Enrollment and Outcomes: Require all segments to report periodically on enrollment and performance-related data pertaining to distance education.

The report suggests biennial reports from all education segments (community colleges, CSU, UC) on workload, number of students served broken out by delivery method, course completion rates for those students, program completion rates for fully online degrees. This seems like a reasonable request, but could be difficult to get comparable numbers across all the institutions in the state.

There also was an announcement yesterday from the University of California that it had: “issued an invitation to faculty to participate in a rigorous pilot project designed to test whether undergraduate online courses can be taught in a way that delivers UC-quality instruction.” It will be interesting to see how (or if) the UC experience might inform this experience. It would be great to get a definition of “UC-quality instruction”, too.

3) Address Transfer: Require the California Virtual Campus and the CSU to provide status reports on implementation of a planned online transfer pathways project.

Students must now jump through several hoops to determine if a course will transfer from one state institution to another. It’s even worse when going from a community to four-year college. The report cites a pilot project in the Bay Area (Go Giants!) that will first provide automated ways to determine transferability and may later grow to common registration procedures. The report suggests reports on transfer issues at this time. This is a good idea, but won’t be implemented in a large way any time soon.

4) Build Online Repository: Establish competitive grants to develop a repository of online course-work that would be made available to faculty throughout the state.

The report recommends that the Legislature “earmark a small portion of each segment’s existing funding for the development of distance-education courses.” These resulting course materials would be made available through MERLOT. The intellectual property would stay with the developer. This would be more money for curriculum to be listed in MERLOT. This will expand MERLOT’s offerings, but without more integration into the academic fabric or faculty incentives to use the materials, I predict that this recommendation will have little or no impact.

5) Consider Shared Programs: Require the review of new programs to consider the possibility of the shared distance education programs instead.

This item really interested me since I recommended several consortia for their review. The California Postsecondary Education Commission (CPEC) has review criteria for proposed new programs and it makes recommendations regarding those proposals to the Legislature and the Governor. CPEC suggests alternatives that could achieve the proposals goals more efficiently or more cost effectively. This strikes me as a very passive way to promote collaboration. CPEC will need to be more proactive in suggesting programs that are good candidates for collaboration and promoting inter-institutional planning. It does not just happen.

6) Add Degree-Completion: Require the Chancellor’s Offices of CSU and the community colleges to study the feasibility of establishing an online degree-completion program for state residents who started college but never obtained a degree.

This is a great idea and more attention is needed to serving returning adults. The report cites the University of Texas system’s “Bachelors’ Accelerated Completion” program, which will serve students having more than 60 credits toward a degree. Texas’s program plans to offer online courses taught in 7 to 8 week terms. The Texas program is new and I suggest they also look at existing models in other states.

7) Consider WGU-California. Create a task force to pursue development of a Western Governors University “virtual campus” in California.

This is the height of irony as California initially shunned WGU because the state could do it all on their own. But, that’s ancient history. The WGU Indiana model has promise and should be explored. Congratulations to the authors for making this recommendation. While they are at it, they should explore other possible partnerships. It’s a big state. Could working with other non-profit or for-profit institutions help to meet a variety of needs and the meet the scale that will be required?

What do you think of these recommendations??

Access, Collaboration/Community, Completion, Legislation, Outcomes, Quality

Uncategorized

Distance Ed Institutions May Need More State Approvals

By Russ Poulin

October 28, 2010

4 Comments

The U.S. Department of Education may be requiring institutions that offer distance education courses to meet the state approval requirements for each state in which the institution enrolls students.

This morning, I have been sifting through a new “Program Integrity Issues” document released by the Department and posted by Inside Higher Ed this morning. The document includes comments made by individuals, institutions, and organizations on the recent Notice of Proposed Rule Making (NPRM) on federal financial aid issues. The “Program Integrity Issues” document (all 894 pages of it) also includes the Department’s responses to these issues and their changes to the original rules they proposed.

I’m not a lawyer, but I’m doing my best to understand what is being required. Also, there are many issues in this document that we’ll need to address. This issue of state approvals was brought to my attention last night and could have a huge impact.

The following is excerpted from pages 214-215:

If an institution is offering postsecondary education through distance or correspondence education in a State in which it is not physically located, the institution must meet any State requirements for it to be legally offering distance or correspondence education in that State. An institution must be able to document upon request from the Department that it has such State approval.

A public institution is considered to comply with §600.9 to the extent it is operating in its home State. If it is operating in another State, we would expect it to comply with the requirements, if any, the other State considers applicable or with any reciprocal agreement between the States that may be applicable.

“Subsection 600.9” is a phrase that will become familiar to us. In that section, the Department is expecting that:

All institutions (whether they offer distance ed or not) be approved by name by the state(s) in which they operate.
The institutions must be approved to offer postsecondary degrees. Having approval to operate as a business in the state does not appear to be adequate. There are lots more complexities to this that I will not explore at this time.
The state must provide a way for students to complain about an institution.

On this last issue, pages 209-210 has the following statement:

With respect to an institution offering distance education programs, the institution must provide, under §668.43(b), not only the contact information for the State or States in which it is physically located, but also the contact information for States in which it provides distance education to the extent that the State has any licensure or approval processes for an institution outside the State providing distance education in the State.

Not sure I fully understand that, but it does seem to place a requirement on institutions to notify students of how to complain.

Hey! Did I mention that this is all to be in place by June 30, 2011? There are some opportunities for institutions to seek extensions, but my calendar has that date as only eight months away.

I was asked, “isn’t this the current expectation?” As I understand it, technically, it is. However, states vary widely in how they’ve applied their regulatory focus. For example, California had no such agency for a few years. Also, it is new that the U.S. Department of Education could demand proof of your approval status. That’s new. What does not having approval mean? It might mean those students are not eligible for federal aid. I’m just guessing.

That’s all I have from the document for now.

There has already been some conversation among organizations about how we can work closely to address this.

If you have comments , more details, or better interpretations, I’d love to hear them.

I will continue to keep you informed!

Regulation, State Authorization, U.S. Department of Education

Uncategorized

The Quality of Elearning — The Debate Goes On

By Russ Poulin

October 14, 2010

2 Comments

The question about the quality of learning in technology-mediated instruction still lingers. Regardless of the evidence provided (U.S. Department of Education’s meta-analysis, No Significant Difference studies) about the quality of the outcomes, there are always detractors.

At the same time that the Gates, Hewlett, and Lumina Foundations have increased their emphasis on technology-mediated learning, I’ve also seen a host of articles recently raising questions about online education.

Congress questioning how well members of our military are served by online classes.
Online lab courses being rejected if found in transcripts of those applying to some health-related degrees.
The Open University’s debate on elearning.

This week I had the pleasure of attending the Presidents’ Forum of Excelsior College’s annual meeting. One session asked the question” “Why Are We Still Addressing Questions About Quality?” I’d like to share some observations that came from that session that was moderated by Julie Prosky Hamline, executive director of Maryland Online.

Photo of Russ Poulin — Russ – Thinking about Quality

Judith Eaton, president of the Council for Higher Education Accreditation, gave six responses to the quality question for elearning:

We need to talk about quality. Educational quality should always be at the forefront.
We need to be defensive. If we don’t define the measures of quality, somebody else will do it for us.
For online learning, expectations are still being established. Many faculty and administrators from traditional backgrounds are still hold a strong negative bias on this issue.
The structure of traditional higher education stands in the way. It is much decentralized. Faculty are “independent entrepreneurs” Does quality imply compliance approval? Will academic freedom by compromised?
Accreditation is a formative, not summative, evaluation. It provides indicators of progress and not the final answer on the quality of anything.
The world is changing. The world of increased demand for higher education and “massified” instruction has put pressures on traditional norms of quality.

Ron Legon, executive director of Quality Matters, noted that the federal and foundation initiatives focused on college completions are again turning our attention to quality being focused on outcomes. Rankings (such as those performed by U.S. News) are based on inputs. If we focus on outcomes, that data should be used for improvement purposes, not just as a rewards and punishment system.

Bruce Chaloux, director, Electronic Campus, Southern Regional Education Board, said that the debate is less about quality and more about credibility. If it was an issue of quality, could we continue to attract a growing number of students each year? What would happen if we suggested doing a Quality Matters review of every course on campus? That would be an interesting discussion to have on campus. If we moved to more competency-based forms of assessment, then the form of instruction matters less.

As part of the question and answer period, Pam Tate, president and CEO of the Council for Adult & Experiential Learning, said that not everyone in industry is convinced of the quality of online instruction. Because of the negative experience of a few employees, one company recently barred it’s staff from using their tuition-reimbursement benefits for online courses. Heavy sigh.

There was much discussion about the need for higher education to better use data to improve student retention and as a measure for outcomes. Of course, this is true regardless of the mode of instruction.

The conversation ended too soon, but we are all living the debate every day. Improving our use of data and analysis will be key. One of the reasons we have not been successful in ending this debate is that the “traditional” side is not required to supply data. How do they measure quality?

How much data is enough? Wish I knew. But I have to believe that an academic community that values research and evidence will come around someday.

What do you think?

Outcomes, Quality, Retention

Uncategorized

For-Profit Hearing: Legislation Might Include All Colleges & Greed is Good

By Russ Poulin

September 30, 2010

3 Comments

“I can assure you that this committee will be exploring legislative changes.” That statement came from Sen. Tom Harkin (IA), chair of the Senate Health, Education, Labor & Pensions (HELP) Committee at the end of the third hearing on for-profit colleges that took place this morning.

Today’s hearing had elements of theater and the most sharply-divided partisan politics to date. Senators Enzi, McCain, and Burr each made the point that the Democrats were being unfair in singling out the for-profit institutions. Senator Enzi, the ranking minority member on the Committee, followed up with a statement released on the HELP webpage. Enzi said. “It is naïve to think that these problems are limited to just the for-profit sector.”

Other highlights from the hearings:

Senator Harkin (IA) – Chair, Senate HELP Committee

Senator Enzi made a point about how “servant leadership” is helpful in driving free and open markets. In making the point, he came dangerously close to saying “greed is good,” but backed off just in time.
Danielle Johnson from Iowa testified about how she felt she was lied to by representatives of Kaplan University.
Arnold Mitchem, President, Council for Opportunity in Education, provided testimony about the trouble that low income or first-generation students have in navigating higher education and the for-profit sector. Finances in higher education is confusing and accreditation is confusing. Those without college experience do not know the right questions to ask. They think they are dealing with counselors and not sales people.
Kathleen Bittel is (or now was?) a career counselor for Educational Management Corporation, which operates The Arts Institutes, Argosy University, Brown Mackie College, and South University. She was one of nine career counselors serving three of those four colleges. She said her job was not about helping student and was focused on obtaining proof that 85.9% of their students were employed in skill-related employment with more than$30,000 in annual salary.
Lauren Asher , President, The Institute for College Access and Success, spoke to her organization’s support of “gainful employment” legislation. She also was articulate in addressing the shortcomings of using the current graduation rates collected by the U.S. Department of Education.
Senator Richard Burr (NC) apparently missed the memo to Republicans to boycott the hearing. Senators Enzi and McCain made brief appearances long enough to read statements and immediately exited the hearing room. Senator Burr said that he felt that the purpose of the hearing was to eliminate for-profit institutions and thought that is was unfair to tell returning soldiers where they could spend their GI Bill funds.
Senator Jeff Merkley (OR) asked if “student loans should be extended to programs that are not accredited.” Ms. Asher gave a polite lesson on the difference between accrediting institution and accrediting program.
Ms. Asher was also a champion of reviewing the financial incentives for colleges. “We need to shift incentives for colleges to focus on outcomes for students.”

Senator Harkin closed the event by saying that there will be one more hearing in December and that legislation will follow next year. Given the administration’s recent announcement of a delay in “gainful employment” regulations, the heightened partisan nature of this discussion, and the upcoming elections, it will be interesting to see how what is proposed and who is affected will change.

Forprofit Universities, Legislation

Uncategorized

Serving Ready Adults – Resources from Non-Traditional No More Project

By Russ Poulin

September 17, 2010

I spent the last two days at the Non-Traditional No More meeting in Denver. Funded by Lumina Foundation for Education, this WICHE-run project works with five states – Arkansas, Colorado, Nevada, North Dakota, and South Dakota – to identify their “ready adult” population – those adults who are close to having enough credits to obtain a degree but have not yet returned to college.

The project has worked with institutions in the state to identify practices and policies that are barriers to students returning to complete their degrees. There also was great attention to harvesting data from collegiate and other sources to find these students where they are now and to welcome them back to college. Each state reported on the great progress they have made:

Arkansas – developed a lottery-funded scholarship for adult learners and has teamed with Acxiom, Inc. to use their data systems to locate ready adults.
Colorado – Metro State College and the University of Colorado Boulder served as pilot institutions in welcoming students back.
Nevada – developed a “concierge” model for helping ready adults navigate the re-entry processes.
North Dakota – newer to the project, they have a statewide Adult Learners Council that expands interest in this issue across government and business constituencies.
South Dakota – developed a comprehensive set of data about ready adults and policies to assist this population, some of which have been enacted and some that are pending.

The NTNM website has much more links and information about state work to serve ‘ready adults’.

At this week’s meeting, participants heard from several states and organizations that had performed similar work or will help the states meet their goals. Below are brief descriptions and links to those initiatives.

STATE INITIATIVES FROM OTHER STATES

Know How to Go – the Kentucky Version
http://knowhow2goky.org/
Part of the “Know How to Go” network, this Kentucky’s version of a portal informing potential college students on a variety of issues to prepare them for college.

KCTCS Online’s On Demand Modules
http://online.kctcs.edu/modules.html

I’m very intrigued by this idea. They are using on-demand, open-ended, open-exit, competency-based modules that are available at a distance. Courses are run by ‘facilitators’ and students can take the exit exam to test out of the course.

Oklahoma College Start
http://OKcollegestart.org
The state’s official website that provides information about higher education in Oklahoma for students, counselors, and parents. It is designed to be the most comprehensive and current source for college planning for Oklahoma students, beginning as early as middle school.

Reach Higher Oklahoma
http://ReachHigherOklahoma.org
Oklahoma’s flexible, affordable way for adults to complete a degree program at a state institution. With eight-week classes that are mostly online, students are not charged an admissions fee.

Center for Adult Learning in Louisiana
http://www.yourCALLla.org
Serving both new and returning students, these courses are offered at a distance in four and eight-week modules. State institutions have partnered to offer the programs and jointly market them.

REMEDIAL EDUCATION

Education Commission of the States
Getting Past Go
http://gettingpastgo.org

If you are looking for statistics, successful models, and strategies for improving your remedial education processes, Bruce Vandal and “Getting Past Go” is a good place to start. If you have not figured it out yet, we are spending lots of money with poor results in remedial education.

PRIOR LEARNING ASSESSMENT

Council for Adult and Experiential Learning (CAEL)
Virtual Prior Learning Assessment Center
http://www.cael.org/pla.htm

This November, CAEL will be piloting a new service that will offer a course on prior learning assessment to unaffiliated students. As part of the course, students will create a portfolio that they can have assessed for a fee. Institutions will decide to grant credit based upon this portfolio assessment. The project is still looking for pilot institutions. The

above link gives general information about prior learning assessment. If you are interested in the Virtual Prior Learning Assessment Center (they are changing the name) or in having your institution serve as a pilot site, contact Judy Wertheim at jwertheim@cael.org.

Russ Poulin
Deputy Director, Research & Analysis
WICHE Cooperative for Educational Technologies

Competency-based Education, Completion, Cost of Instruction, Prior Learning Assessment

Uncategorized

Last Day of Attendance: Audit Results Should Have You Check Your Aid Procedures

By Russ Poulin

August 27, 2010

2 Comments

Just a hint…you may want to review your financial aid processes for distance education.

Thank you to Michael Jortberg from Acxiom for alerting me to a small item in this morning’s Chronicle of Higher Education postings: Audit Finds Errors in Baker College’s Distance Education Attendance Records. As you may know, WCET has been following this issue with the help of Dow, Lohnes Government Strategies. We have conducted a survey of members on this issue and issued a joint letter with ACUTA and UPCEA to the Department.

Over a several year period, the U.S. Department of Education has been reviewing the “last day of attendance” calculations for students who unofficially withdraw or drop-out of their online courses. From a brief from Dow, Lohnes Government Relations on this issue:

“if the institution is not required to take attendance, as is the case with many collegiate institutions, the institution may either use the mid-point of the financial aid payment period as the effective withdrawal date or it may choose to document the student’s LDA in an ‘academically related activity.’”

In the findings from the U.S. Department of Education’s audit of the institution, Baker College (Michigan’s largest non-profit, independent college) was cited for:

The College did not maintain records that were adequate to support its determination of student attendance during Award Year 2006-2007.
The College incorrectly identified when distance education students began and ceased attendance.

As a result of the audit, Baker College will have to refund $9,790 in financial aid funds for a handful of errors found through the audit process. They are asked to review the records of an additional 2,238 students and reimburse the U.S. Department of Education for any amounts that do not meet the standards laid out in this audit report. Baker College is also asked to verify the first day of attendance for these students, which is new to me. But, I’m not a financial aid person.

Now, an amount just under $10,000 does not sound like much. Undoubtedly, this has already cost considerable staff time and will require more staff time to perform the reviews of the records of each of these students. A large amount of additional reimbursements will probably ultimately be uncovered.

WCET is not in favor of sloppy procedures or defrauding the government. We just want clarity in definitions.

The U.S. Department of Education cited Baker College for a lack of definitions in its findings including criticizing it because it “did not provide a definition of ‘academic posting’ to its instructors.” Similarly, we would like to see clear definitions and guidelines provided by the Department on this issue. Colleges should not to have to wait for audits to see if their procedures are in compliance.

Our most recent letter to the Department concludes:

Given the importance of this matter for a great many institutions, we request that the Department define prospectively the documentation that our institutions may use to evidence LDA for online programs that would be effective beginning with the 2011‐2012 award year. This would provide sufficient time for institutions to make any modifications to their systems and procedures to comply with the Department’s new definitions. We also request that the Department take no adverse action against any institution for its LDA calculation until the Department issues that definition.

Meanwhile, what should you do?

If you are a distance education or financial aid administrator, I’d read this audit report and ask myself, “Do our procedures meet the standards cited in these findings?”

Russell Poulin
Deputy Director
Research & Analysis
WCET

Financial Aid, U.S. Department of Education

Practice

Welcome to WCET’s New Frontiers Blog

By Russ Poulin

July 22, 2010

It’s exciting that WCET is starting a new blog.

There is so much that is interesting that is going on in the distance, online, and hybrid learning spheres that we need more ability to share with each other. In the average week, WCET staff have many conversations with thought-leaders and cutting-edge practitioners. We’d like to share with you what we’ve learned as we learn it and we want your feedback.

From the blog, you can expect:

Policy Analysis. We’ll examine emerging e-learning policy issues as they are happening. We’ll feature some of the analyses from our News Digest & Analysis mailings. We’ll also feature issues from our Advocacy and WCET Focus Area Agendas.
Guest Blogs. We’ll invite other to comment on policies and practices that have an impact on members. We’ll also point you to interviews from our new “Conversations with…” feature.
Buzz. Heads-up pieces on trends that we are seeing and the “buzz” we are hearing.
Thinking-out-loud. There are often ideas or issues that are not ready for full-blown articles, but we will want to throw out to our members to get your opinions.
Fun. Sometimes we can’t resist sharing something that makes us laugh.

We look forward to sharing with you and hearing back from you.

Russ Poulin
Deputy Director, Research and Analysis
WCET Blogologist

WCET