Author: Russ Poulin

How a Technical Call Center Added Financial Aid Calls – and Thrived!

By Russ Poulin

July 16, 2015

2 Comments

After 10 years of providing technical support for e-Learning solutions, the Connecticut Distance Learning Consortium’s (CTDLC) Call Center was presented with an interesting opportunity. The CFO of our parent organization, Charter Oak State College, approached us to ask whether we could help him with a data gathering project. He wanted us to answer the phones in the Financial Aid Office for a few weeks and record basic information so he could better understand the volume of calls coming through and the nature of the calls.

At the time, the Financial Aid Office was drowning in work and advocating strongly for an additional full time position. The president of the college was concerned because students were calling other offices, including his, desperate for Financial Aid help. The information gathered was to be used to support a staffing decision.

Financial Aid: “How Hard Can it Be?”

Our initial response, “We’re a technical support center and don’t know anything about Financial Aid.” We’re used to answering questions about LMS logins, computers malfunctions, and network down time, not about arcane federal regulations.” Our concerns were quickly answered with, “But how hard could it be?” After meeting with the Financial Aid Director for the initial 2 hour training session, we began to comprehend the complexity of the Financial Aid process and started wondering what we had gotten ourselves into.

After another 2 hour training session and read-only access to the Financial Aid system, the Financial Aid office phone was redirected to our call center and we were off and running. We quickly realized that the Financial Aid process can be quite anxiety producing because the outcome likely determines where a student will go to school and in many cases, whether a student will be able to afford to go to school at all. We worried that our technical support staff did not have the skill set to serve this category of calls.

We Survived, We Learned, We Got Cookies

The pilot lasted about 6 weeks and the outcomes surprised all of us. The CFO was humbled by the sheer volume of calls the office was receiving and was able to fully appreciate the challenge that the Financial Aid Staff was facing. The Financial Aid Staff was so grateful to have the ability to focus their efforts on processing FAFSA applications and packaging awards that they baked us cookies. The also reported improved processing times and employee morale.

Most importantly, prospective and current students were thrilled and relieved to have their call answered. They loved being able to receive help seven days a week. The feedback we received was overwhelmingly positive, prompting the realization that this was an area where we could add real value.

We also learned that our staff, comprised of student workers, were excellent at this type of work. As college students themselves, they approached each caller with empathy and patience, able to alleviate the student’s anxiety around the process and explain the next steps in a way that made sense to them.

And so, a new line of business was born.

We Used Data to Improve Our Processes

The report we generated for the CFO contained a wealth of knowledge that could not have been obtained without call center tools and processes. We were able to take the data we collected and perform root cause analysis. We determined that there were 3 categories of requests: process questions (How do I?), status questions (What’s my status?), and award-specific questions (Why did I get this amount?).

The call center had the knowledge and system access to answer virtually all the process and status questions. Any discussions around specific dollar amounts were escalated to the Financial Aid Office. We found that over 75% of all calls were being resolved on the first call by our staff. This was such a big number, all of us were somewhat shocked. We also realized that callers were often asking the same 15-20 questions and that many of these could be eliminated through process changes or clarifying language on the website or outgoing communications.

We Became the Call Center for Five Colleges. Student Satisfaction is High.

The pilot was so successful that the request for a full time position in the SFA office was replaced by a request to have the call center service become a permanent solution. Five years later, we are still taking those calls and have expanded our service to four additional colleges. The service has become more sophisticated and our reports include actionable data.

We have recently introduced a student retention element to our data gathering and will partner with institutional retention specialists to identify high risk students and escalate for immediate intervention.

We have shown that our service not only increases productivity within the SFA office (contributing to student retention efforts), but we frequently receive calls from students that start with “I know this question is not about Financial Aid but you guys always answer the phone and I really need help….” Clearly the other academic offices at Higher Ed institutions are busy too and can find it difficult to answer the phones consistently. We always do our best to answer these questions and find that we are often able to help. Cliff Williams, CFO at Charter Oak State College reports that “The CTDLC Call Center has become an integral part of the college’s Financial Aid Office, providing our staff the ability to focus their efforts on processing Aid, ensuring compliance with Federal Regulations and implementing process improvements. Students are receiving the service and attention they deserve and enrollments are up. It’s a win-win for all concerned.”

We continue to provide monthly reports and real time feedback when we see a process or communication that could be streamlined or re-worded to reduce confusion. As a direct result of these efforts, every school we support enjoys a reduction in calls each year. We have also found that the number of calls we are able to resolve ourselves is now closer to 90%. CTDLC’s Executive Director, Kevin Corcoran, thinks we are going to put ourselves out of business if we keep this up.

We look forward to the day when the process is so smooth that the phones stop ringing!

Cathy Bergren
Connecticut Distance Learning Consortium
Director of Service Delivery

Photo credit for person on headset: MorgueFile

Collaboration/Community, Consortia, Financial Aid, Managing Digital Learning, Student Success, System/Consortia

Uncategorized

Update on the Five Types of State Authorization Regulations

By Russ Poulin

June 28, 2015

1 Comment

Hello from Washington, DC and the NACUA (National Association of College and University Attorneys) Annual Conference. As part of my role on a state authorization panel, I was asked to give an overview of the Department of Education’s state authorization regulations. After the U.S. Department of Education’s recent announcement that it expects states and institutions to comply with the “on ground” state authorization rule beginning July 1, I thought this update would be timely for all.

Question: You are asked to give an update to the Board of Trustees on the Department of Education’s state authorization regulations. What can you tell them?

In response to your question, I’d try to totally baffle and confuse the Board of Trustees by telling them about the five different types of state authorization requirements that an institution could face. While it’s confusing, they need to see the whole picture as a partial answer may lead them to make an incorrect decision.

It’s the proverbial blind men trying to describe the elephant. If you don’t get the whole picture, it’s easy to get it wrong. I’ve heard numerous campus leaders demonstrate their knowledge about one of these sets of requirements while ignoring all the others. If your goal is mitigating risk, you want to inform your Trustees about as many of the regulatory potholes as they are willing to learn about.

State regulations regarding institutional authorization – This is not a federal regulation, but the regulations that each state has constructed. The state authorization regulations in each state have been around for many, many years. If your institution is serving students in another state, the state where that student is located when receiving the bulk of the instruction expects you to follow their state laws and regulations. It’s all about location and not official state of residency. Each state has its own history and politics surrounding the creation and changes to their regulations. Therefore, the criteria regarding if your institution needs to seek approval varies greatly from state to state. All states seem to expect you to be authorized if you are clearly physically located in a state, such as owning or renting a building in their state. Beyond that, the measures of what is termed “physical presence” vary greatly. About a dozen states require you to obtain approval if all you are doing is offering distance education in their state. However, if you are conducting additional activities in that state, you could trigger their “physical presence” definition. Examples of such “physical presence” triggers include holding an internship in a state, direct marketing in a state, requiring students to go to a particular place for a proctored exam, or having an employee in a state. Depending on the state, performing any of those acts may trigger their expectation for you to be approved in their state. You need to check the rules of each state.
State regulations regarding licensure programs – If you have a program that leads to licensure in a profession (such as teaching, nursing, psychology, and a host of medical professions), the boards that oversee each profession may have additional requirements. For some professions they want to approve each and every institution that prepares students who participate in clincals or sit for their licensure exams in the state. Failing to properly notify students about licensure requirements is probably the top risk facing campuses serving students in other states. The U.S. Department of Education added additional notification requirements onto the Gainful Employment regulations and I expect the Department wanting to add these notification requirements to other regulations that may be coming.
U.S. Department of Education regulation for “on ground” programs” (Chapter 34, §600.9 (a) and (b)) – After four years of delays, beginning July 1 of this year, the Department will expect you to do two things (see more details in the Federal Student Aid Handbook):
- Regarding your institution’s “home” state: Be able to identify the state oversight agency that authorizes you to grant postsecondary degrees in your home state. Additionally, you need to identify the complaint process that a student can use to complain to the oversight agency about your institution. This requirement is for all institutions that grant federal student aid regardless of institution type. Institutions that think they are exempt from state oversight (unless they are authorized by the federal government of an Indian tribe), better look into this one.
- Regarding face-to-face programs in other states: You should look around your institution to determine if you have any “on ground” programs in another state. Using the financial aid definition of “location,” this is a program in which “at which it offers or will offer 50 percent or more of an educational program if the institution wants to disburse title IV, HEA program funds to students enrolled at that location...” If you have such a program, you will be expected to identify the oversight agency that approved your institution’s ability to offer programs in that state and identify the complaint process for that oversight agency, as well. This does not apply to programs offered via distance education, unless they have a significant face-to-face component that exceeds the “location” definition. For a more complete discussion of the “on-ground” vs. “distance education” distinction, see the WCET Frontiers blog post by Greg Ferenbach and Matthew Johnson of Cooley, LLP.
U.S. Department of Education regulation for “distance education” programs (Chapter 34, §600.9 (c)) – This one is easy. The regulation was set aside by the federal courts on a technicality. After a failed Negotiated Rulemaking attempt last year (I represented the “distance education” constituency on that Negotiated Rulemaking Committee), the Department has “paused” on reissuing the regulation. To me, it appears increasingly unlikely that they will issue a new regulation this year, but stranger things have happened. To repeat, there is no Department of Education state authorization for distance education regulation currently on the books. UPDATE (06/29/15): At the NACUA meeting on 06/29/15, U.S. Department of Education Under Secretary Ted Mitchell announced that the next steps for their “distance education” regulation is “down the line.” I interpreted that to me not this year and probably past his time in office.
U.S. Department of Defense MOU – Institutions offering Tuition Assistance (that’s a form of collegiate aid to students in the military) had to sign a new Memorandum of Understanding last year. That MOU requires that institutions: “Comply with state authorization requirements consistent with regulations issued by ED, including 34 C.F.R. 600.9. Educational institutions must meet all State laws as they relate to distance education as required.” I attended the Council of College and Military Educators conference earlier this year and colleges attending that meeting were gearing up to be in compliance for fear of losing the ability to offer Tuition Assistance funds.

Remember, regardless of what the federal regulations say, the states still expect you to be in compliance with their laws and regulations.

In talking to your Board of Trustees, you may want to let them know that there are no simple answers to these questions. When I get questions, I always fall back on the truthful (if unsatisfying) phrase “it depends.” The answer to each question lies at the intersection of the following three variables:

What type of institution you are (public, private non-profit, private for-profit)?
What activities does your institution perform the state in question?
Do the regulations for the state in question require you to get approval before you conduct those activities?

Remember that is examining your requirements for just one state. Once you multiply it times 49 other states, the District of Columbia, other territories, and other countries, it can get a bit complex to understand.

For more information, see WCET’s State Authorization page: http://wcet.wiche.edu/learn/issues/state-authorization

Russ

Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

If you like our work, join WCET!

Complaint Process, Distance Education, Physical Presence, Regulation, SARA, State Authorization, Title IV, U.S. Department of Education

Practice

Implementing a CBE Program: Lessons Learned from Community Colleges

By Russ Poulin

June 11, 2015

1 Comment

“We are introducing a disruptive model into the traditional college campus. Nothing will be the same once you take the time orientation off the table.” Tom Nielsen (Bellevue College)

Tom shared that wisdom at last week’s CBE4CC event, which brought together hundreds of community college faculty and administrators from throughout the U.S. They shared their progress and hopes for implementing competency-based education (CBE) programs. The Bill & Melinda Gates Foundation, Western Governors University, and several community colleges hosted the session aimed at sharing lessons learned.

There has been tremendous growth and innovation in CBE. This is especially true in programs that map well to specific occupations. While it is hard to summarize all that was shared at this event, below are some of my key takeaways.

Completion Rates for CBE Programs are Quite High
Presenters commonly reported completion rates of 75 to 90% for their CBE programs. Some of the colleges’ rates could have been higher. Some students left early because they were offered jobs based on what they had learned so far. Upon graduation, employment placements often approached 100%.

Effective Recruiting, Advising, and On-boarding Students is Essential
Recruiters and marketing efforts need to acknowledge and celebrate the unique nature of CBE programs. Even though community colleges are typically open enrollment, the CBE programs determine whether an applicant is a good fit for the program. Several colleges use Smarter Measure to evaluate student readiness. To that tool, some colleges add assessments (e.g., math and writing) to help assure student “fit.” Orientations are commonly used to increase student success. CBE courses differ from those that students’ previously experienced and they need to be alerted to those differences.

Coaches / Mentors / Advisers (Whatever You Call Them) Are Key to Success
Colleges use non-faculty personnel who are assigned a students to assist. The Coach (colleges vary in what they call them) identifies possible obstacles, monitors student progress, contacts the student (often weekly), coordinates with the student’s faculty, and helps the student stay on track to meet his or her goals. Ed Sargent of Edmonds Community College said that he would never run an online program without a Coach, whether it is CBE or not. According to Ed: “They are why we have a successful program. Student mentors remove excuses.”

Communicating about “Pace” is Important
One college stripped all reference to “self-paced” from their materials because students thought they could take as long as they wanted. That college switch to “accelerated” to change the student mindset from leisurely to active pursuit of success. “Pacing charts” set benchmarks that students should meet if they want to finish the course more quickly. The same course may have several “pacing charts” (16, 12, 8, 4 weeks) to accommodate the ambitions of different students. The Coaches work with the students on a setting a pace that meets current needs. If a pace is too fast for a student, she or he will fail.

Unbundling Faculty Roles is an Unnatural (but Necessary) Act
CBE allows colleges to “unbundle” all the roles traditionally assigned to faculty, such as: course development, assessment development, facilitation, grading, student performance monitoring. If you were to create a spectrum of that ranged from faculty fulfilling all their traditional roles to a completely unbundled model (such as WGU’s), the colleges at the meeting would land all across that spectrum. If you do unbundle roles, it was recommended that faculty be included early and often in the decision-making process. There also was a mix of engaging senior faculty, adjunct faculty, or hiring completely new faculty for the CBE program. In any case, set clear roles, expectations, and boundaries for everyone.

Decide on Buy, Share, or Build Content Models
While Department of Labor’s TAACCCT grants specifically incentivized the creation of open educational resources, the reuse of such materials appeared to be minimal. Most seemed to have built their own content or purchased content from publishers. As the CBE matures, the opportunities to share or buy content are growing.

Working within Your Systems
Most colleges can’t purchase an SIS or LMS that is dedicated to CBE, so you often have to work with what you have. Annie Myers of Broward College advised us to avoid manual workarounds. If you are thinking about sustainability, build CBE processes into your systems from the start. Sam Greer (Austin Community College) lamented about his system’s ability to handle transcripts only to have a colleague from another college point him to the “athletics module.” In researching her suggestion, he found that there are often alternatives already built into many systems.

Expect Pushback
CBE is a different way of doing business for faculty, administrators, and students. Any time there is change, expect pushback. Find those from other CBE colleges who are doing the “impossible” and learn from them.

Picture of Sam Greet in front of projection screen with many logos on it. — Sam Greer (Austin CC) with the logos of their many corporate partners.

Collaboration Helps
There were great examples of how colleges were able to overcome some obstacles by working in partnership with others. The Washington State Board of Community and Technical Colleges leveraged existing support systems and shared development costs. Austin (TX), Broward (FL), and Sinclair (OH) Community Colleges are an unlikely grouping, but they have benefited by learning from the advances made by the other two colleges.

Sustainability is Still An Issue
Some creative means of obtaining corporate involvement in the program were shared, but that was mostly at the program advisory and recruiting functions. Sam Greer (Austin Community College) advised us not to count on corporations paying for any portion of on-going development or operational costs. It was my observation that there several CBE efforts were bolted onto existing structures at the campuses. In my opinion, if you are not rethinking your structures (unbundling faculty, replacing some functions with CBE functions) then your costs will only increase and sustainability will be more difficult. On the positive side, higher completion rates means that money can be saved on retention and recruitment of students.

NOTE: On June 9 (after the CBE4CC event) the U.S. Department of Education released its long-awaited take on how it will regulate CBE programs. More on this to come.

Thank you to Nancy Thibeault (Sinclair Community College) and Sally Johnstone (WGU) for asking me to help out at the event. I believe that CBE4CC will share additional information on outcomes from the meeting and any future events on its website.

Great job in sharing by all involved. Congratulations to the Foundation, WGU, and the community colleges who lead this effort.

Good luck in implementing CBE!

Russ

Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

If you like our work, join WCET!

Credit for graduate photo: Morgue File

Accreditation, Collaboration/Community, Competency-based Education, Completion, Open Educational Resources, Outcomes, Student Success

Practice

Four Recommendations for the Higher Ed Act Reauthorization

By Russ Poulin

June 4, 2015

6 Comments

Some new federal regulations may be coming your way and we need to make our voice heard. We need your help in addressing concerns in four areas: ensuring equity for financial aid, student identity, accessibility, and state authorization of distance education.

The Higher Education Act

This year we celebrate the 50th anniversary of the Higher Education Act of 1965. It’s long title declares it to be: “An Act to strengthen the educational resources of our colleges and universities and to provide financial assistance for students in post-secondary and higher education.”

The 1965 version of the Act was 58 pages.

The Act was the beginning of Congress’s attempt to codify the relationships that the federal government has with higher education. Over the years, the rules for institutions to remain eligible to offer federal financial aid have grown. Congress uses it as a hammer to impose additional requirements on colleges. Although the Act is supposed to be “reauthorized” every five years, the last time such action was taken was 2008.

The 2008 version weighed in at 432 pages. Seven years later, the Department has yet to implement all of the provisions growing out of the last Act. Life is more complicated, I guess.

We Need Your Help

Congress is finally moving forward on the next reauthorization. Hearings are being held and we think that they may actually have some success in taking real action.

We’ve identified four issues (regarding distance education and technology-mediated learning) on which we would like to see (or not see) action. There are more, but these items rose to the top in several recent discussions with Steering Committee representatives, advisors, and WCET members.

Below is a brief outline of the issues. We need your feedback and invite you to let us know if there are others that should be added to the list.

The Four Issues

1) Ensuring Equity

Think of a college student. Did you think of a young person between 18 and 22 who lives on campus? Increasingly, that is not the norm. Unfortunately, policymakers are often unable to overcome the fixation on the “traditional” student.

Context

Thank you to Christina Sedney of the Adult College Completion Network for unearthing the following statistics from the CLASP brief “Yesterday’s Non-Traditional Student is Today’s Traditional Student” (Updated January 14, 2015):

Four in 10 undergraduate students are 25 years or older, a 4 percentage point increase from 2008[i].
From 2012 to 2022, the non-traditionally aged student enrollment in college is projected to grow more than twice as fast as for traditional age students (8.7% and 21.7%, respectively)[ii].
51% of undergraduate students are classified as independent (meaning: 24 years or older, married, responsible for legal dependents other than a spouse, orphans or wards of the court [or were wards of the court until age 18], veterans of the U.S. armed services, or homeless or at risk of homelessness)[iii].

Recommendations

What we would like to see:

1.1 Financial aid rules should treat learners equally as much as possible, regardless of mode of instruction, full-time/part-time status, month of the year, or other irrelevant characteristics that disadvantage the non-traditional learner. Specifically, don’t limit aid just because a student is taking distance courses.

1.2 Return to the year-round Pell Grant.

1.3 Develop reasonable accommodations for educational innovations, such as competency-based education, adaptive learning, prior learning assessment, alternative providers, and innovations of which we’ve not yet dreamed.

2) Student Identity / Fraud / Academic Integrity

We’re all against fraud, which is the act of criminals using false identities to steal financial aid funds. This is a criminal activity and robs honest students of funds that could be available to them.

We’re all for academic integrity, which is keeping students from cheating on tests, papers, and assessments. While not a criminal activity, it devalues the work of honest students.

Context

In February 2014, the Department of Education’s Office of Inspector General (OIG) released a scathing report regarding the Department’s and colleges’ lack of efforts in curtailing financial aid fraud. While the report makes some excellent recommendations, there are places in which they confuse fraud and academic integrity. Solutions for one may not work or may be too onerous for the other. The Department was supposed to issue a response by the end of Spring of 2014, but it has yet to be published.

Recommendations

What we would like to see (based on the recommendations from the OIG report). Some of these recommendations might best be handled outside of HEA, but are added for completeness sake. See my earlier blog post for a more complete discussion:

2.1 Institutions should verify student identify at enrollment. This should apply to all students, not just distance education students.

2.2 Reject the OIG’s recommendation to have independent auditors review student identify verification systems.

2.3 Require more frequent disbursements of aid. This should apply to all student, not just distance education students.

2.4 Better define first and last day of attendance for students who withdraw without officially notifying the institution. Simplify current, poorly defined rules, that greatly disadvantage and burden colleges offering distance education.

2.5 “Cost of attendance” calculations for students should reflect true costs. We reject earlier attempts to arbitrarily strip distance education students of the ability to count living expenses or computing costs as part of their “cost of attendance.”

2.6 The OIGs report does not address what may be the best deterrent to problems regarding student identity, that is education of front-line employees, such as faculty and student services staff. If they know what behaviors to monitor, they will catch unwanted activities much quicker than most of the other recommendations combined.

3) Accessibility of Educational Technologies

We’re all for equal access to educational technologies for those with disabilities.

Context

Jarret Cummings from EDUCAUSE updated us on the TEACH ACT earlier this year:

“The National Federation of the Blind (NFB) and the Association of American Publishers (AAP) worked with members of Congress last year to introduce the Technology, Equality and Accessibility in College and Higher Education Act (TEACH Act). The bill proposed to foster the development of voluntary guidelines for ‘electronic instructional materials and related technologies.’ Many higher education associations support this goal, believing that voluntary guidelines could help colleges and universities continue to improve in meeting the learning needs of students with disabilities. However, they have concerns that the bill as written would unintentionally hamper the use of technology to advance learning by all students, including those with disabilities.”

I met with Jarret recently. He continues to work with the NFB and others to develop new language that would be more universally acceptable.

Recommendations

What we would like to see:

3.1 Support for the agreement that is currently being forged by EDUCAUSE, NFB, and others. We’ll receive final judgment until we see the final language, but we have great trust in Jarret’s leadership in finding an equitable solution.

4) State Authorization of Distance Education

We’re all for the protection of students as consumers of distance education. In creating regulations, weigh the competing interests of state oversight, federal oversight for financial purposes, and both the responsibility and burden placed on institutions. On the latter point, institutions often highlight the burden while forgetting their responsibilities.

Context

Yes, I’m very much invested in this one. I was on the Department of Education’s Negotiated Rulemaking team last year, which failed to come to consensus on new language for state authorization for distance education. The Department’s negotiators insisted on keeping a provision that would have disallowed states from issuing exemptions to any institution. We continue to object to that provision as it provided no real protection for students, but would have added considerably more work and confusion to the authorization process.

The ball is currently in the Department of Education’s court to issue regulations for public comment. They say that they are still on “pause” with no timeline for issuing the regulation. If it is not issued in the next few weeks, it is unlikely that we will see a new federal regulation this year.

Recommendations

What we would like to see (much of this is taken from the recommendations made jointly by OLC, UPCEA, and WCET last year. While there are more recommendations, I’m highlighting these three in this blog post):

4.1 Return to the 2010 Language. We recognize the affirmation by the U.S. Court of Appeals that the Department can use state authorization as a criterion for offering federal financial aid. As a basis for any future regulation, the Department should return to the state authorization language released in October 2010 that required an institution to “meet any State requirements for it to be legally offering postsecondary distance or correspondence education in that State. An institution must be able to document to the Secretary the State’s approval upon request.”

4.2 Recognize Reciprocity. We recommend that the Department continue to recognize reciprocity as a means to authorization. Through reciprocity, one state recognizes the authorization actions of another state participating in a reciprocal agreement. SARA’s progress to 24 states (as of this post) in less than 18 months indicates the success of this approach.

4.3 Exempt Military, Military Families, and the Veterans Administration Facilities. The Department should retain the proposed provision that exempts active military and their families. They should also work with states to update their state regulations to reflect this exemption.

You Turn – We’d Like Your Feedback

This is obviously an outline of a set of proposals. How would you improve them? What would you add? What other issues should be addressed? Would love hearing from you.

Russ

Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

If you like our work, join WCET!

Photo credit: Stephen Melkisethian

[i] Source: Author’s calculations using NCES PowerStats, Source: “2011-12 National Postsecondary Student Aid Study (NPSAS:12),” U.S. Department of Education, National Center for Education Statistics, calculated 12/09/2014.

[ii] Source: http://nces.ed.gov/pubs2014/2014051.pdf, Author’s calculations using Table 21. Actual and projected numbers for total enrollment in all postsecondary degree-granting institutions, by age group, sex, and attendance status: Fall 1997 through fall 2022, Projections of Education Statistics to 2022, February 2014.

[iii] Source: Author’s calculations using NCES PowerStats, Source: “2011-12 National Postsecondary Student Aid Study (NPSAS: 12),” U.S. Department of Education, National Center for Education Statistics, calculated 12/09/2014.

Academic Integrity, Accessibility, Disabilities, Distance Education, Financial Aid, Higher Education Act, Reauthorization, SARA, State Authorization, Student Authentication, Title IV, U.S. Department of Education

Practice

CCCOnline Finds Success in Six-week Intensive Courses

By Russ Poulin

May 13, 2015

As of summer 2014 CCCOnline has been offering 6-week intensive courses. These have shown great promise in terms of student interest, student success/retention, and instructor satisfaction. Before I embark on this journey we’ve been on, first a little background on CCCOnline: CCCOnline is part of the Colorado Community College System (CCCS) and is composed of 13 Colorado Community Colleges and CCCOnline.

CCCOnline is not its own college, but rather we are a service organization for the 13 CCCS colleges; we provide online courses on behalf of the colleges in our system. It’s a relatively unique set-up and a good story for another day. An interesting note here is that many of the colleges also have their own online offerings delivered through their respective colleges. Now, let’s get back to our experiences with offering shorter intensive term courses.

During the spring semester of 2014, CCCOnline decided to begin a quest to offer 6-week short courses. Previously, our terms were 10- and 15-week terms. We wanted to know:

Were students interested in these intensive online courses?
Which courses would be best to offer in a shortened timeframe?
How would the retention/success rates compare with our 10- and 15-week terms?
If successful, what would be our plans going forward?

And last, our Executive Director wanted a summer 2014 pilot, so an urgent question was

How would we get them developed in time for a summer 2014 pilot?

Were students interested in intensive online courses?

Anecdotally, students often asked if they could finish online courses earlier than the class schedule indicated. Nationally, we were aware of other online schools offering alternatives for students to finish their degrees more quickly. So, the time seemed right to give this a try. After one pilot run (summer 2014) and one full semester run (the spring 2015 semester consisted of a 15 week, 10 week and two 6 weeks parts of term), we found students are definitely interested in these intensive 6 week terms. Compared to the enrollments at our system colleges, due to our 6 week courses, our enrollments for the summer and spring terms were up when most of the CCCS colleges’ enrollments went down. Our 6 week online courses accounted for much of our growth.

Which courses would be best to offer in a shortened timeframe?

Our Associate Deans and Program Chairs were engaged in a conversation on which courses they felt could be responsibly offered in this timeframe. After receiving suggestions from this group, we looked at enrollment numbers for these courses as well as reviewing CCCS’ Associate of Arts and Associate of Science degrees. Courses selected from the suggestions provided by the Associate Deans were those with healthy enrollments (so we were assured of student interest in these courses) as well as courses that could be taken in order to help completion with a 2-year degree. Most of the courses were in our Liberal Arts/Humanities areas and included English, History, Communications, Sociology, and Psychology courses. We also selected a couple of 1-2 credit health care courses as health care programs are in high demand.

How did we get 13 courses developed in time for a summer, 2014 pilot?

During the spring 2014 semester, our Executive Director wanted to go with a 6-week part-of-term pilot for summer 2014. Since there’s no time like the present to jump in with both feet, we decided to go for it.

We had about 3 months to revamp 13 of our courses to a 6-week format. To this end, we contracted with an external vendor to take our 13 pilot courses, redo the schedule and course alignment to fit a 6 week term and fit our courses into our existing Master Course Template. In short, it was a mad scramble but we got it done and out the door. The courses weren’t perfect, but they were good enough to run a successful pilot.

Here are some lessons learned: if you can sufficiently plan ahead and not do a mad dash to the finish line this will significantly lengthen the life of your employees. Also, in hindsight, we probably could have done a quicker, less expensive, and better job if we had kept the work in house and used our internal subject matter experts and instructional designers. Since our timeline was so short, much time was spent communicating back and forth on expectations with the external vendor. If we had kept the work in-house, the work would have been more efficient.

On a side note, we chose instructors who were among our best to teach these intensive courses. As much as possible, we wanted to make sure that for these courses we had instructors who were highly skilled with online teaching and thus would be highly engaging and responsive for the students.

How did the retention/success rates compare with our 10 and 15 week terms?

For the 6-week pilot, we were expecting lower retention/success rates. This happened in some courses but the success rate also happened to be higher in some areas. The average pass rate for these courses was 67.25% and the average DFW rate was 32.77% (the average drop rate was 19.33%). These percentages are more or less in line with our 10- and 15-week terms – we were happily surprised.

Anecdotally, we received comments from student and instructors alike that these courses were indeed very “intense” but the fast nature made both students and instructors very focused on the courses. Many students felt like they learned more due to their higher levels of engagement and instructors were grateful for finishing their teaching duties early and having some time to enjoy the summer.

Some students felt the courses were too fast. Many were able to figure this out soon enough to drop the course without any financial penalty.

What are our plans going forward?

Before the summer 2014 pilot started, CCCOnline committed to not offering any 6-week courses in fall 2014 so that we could assess if: 1) the pilot was successful (it was) and 2) if the pilot was successful, to survey student and instructors on how to improve the courses and then to do so before offering the courses again in spring 2015.

For spring 2015, we were able to add three additional 6-week courses, so currently we have a total of 16 courses (two more being developed). For the summer 2015 semester, we will offer a 10-week term and a 6-week “Fast Track” term. For fall 2015 we will offer a 15, 10 and two 6-week terms. After the fall 2015 semester, we will look at the enrollment, retention and success data for these intensive courses and determine which parts of term to best offer certain courses.

Future plans also include:

Marketing these courses with degree plans so students can plan to complete their degree requirements in a shorter time frame;
Marketing these courses to 4-year students who need a summer course for transfer;
Putting more of a strategic framework around these course by showcasing Liberal Arts/Humanities offerings, CTE offerings, and Healthcare offerings;
Partnering with our system colleges to offer these courses in conjunction with their degree and certificate offerings.

With questions or comments in regards to this topic, please feel free to contact Terry Reeves at terry.reeves@cccs.edu or call at 720 858 2215.

Terry Reeves
Dean of Academic Instruction
Colorado Community Colleges Online
terry.reeves@cccs.edu

Completion, Course Design, Distance Education, Instructional Design, Outcomes, Research

Uncategorized

State Authorization “On Ground” Rule: No More Delays, More Confusion to Come

By Russ Poulin

May 5, 2015

2 Comments

The final state authorization deadline for “on ground” programs approaches quickly

A U.S. Department of Education regulation that outlines steps states must take in overseeing institutions within their own boundaries will take effect on July 1 of this year. It originally was slated to take effect in 2011, but has been delayed by a year for each of the last four years.

At the NASASPS (state regulator) meeting last week, Sophia McArdle informed participants that there will be no more extensions. Beginning in July, institutions that are undergoing financial aid reviews (which we lovingly call “audits”) will be asked to demonstrate that they are in compliance.

Can We Expect Confusion?

Photo of a crosswalk light that has both the don't walk and walk symbols illuminated. — Confused about whether to stay or go on state authorization?

Oh yes.

First, the “on ground” regulations should NOT BE CONFUSED WITH THE FEDERAL DISTANCE EDUCATION regulations that were vacated by the federal courts. The distance education regulation is Chapter 34, §600.9(c). That regulation is not being enforced by court order. While the Department of Education is interested in bringing back the distance education regulation, they currently have not announced a timeline for doing so. Dr. McArdle confirmed that this regulation is still on “pause.” Since many in our sphere associate state authorization with distance education, there will be some panic about this. Please help in allaying their fears.

Second, regarding distance education, state regulations are still very much in place and states expect you to follow their laws. Some people are still in denial about this.

Third, while there are only a few provisions to the “on ground” regulation (see Chapter 34, §600.9(a) and (b)), guidance from the Department has sometimes been confusing. While many states were in compliance from the start, a few states that needed to make changes were slow to respond.

What is Expected of Institutions (and Therefore States)?

The Department of Education can’t force states to adopt regulations or practices. To obtain federal financial aid, the Department can place many demands on institutions. They can “entice” states to want to follow a prescribed course of action.

To get the states to change their ways, the requirements are placed on the institutions. The loss of federal aid is a good enticement. I have a mental image of a driver waving a police officer over and requesting the officer search the car. It’s just not normal.

In brief, the state must authorize EVERY institution that seeks federal aid and must have a “process to review and appropriately act on complaints concerning the institution including enforcing applicable State laws .” For a more complete explanation, see a great post from Greg Ferenbach and Matthew Johnson of Cooley, LLP.

Who is at Risk?

Mostly institutions that don’t think they report to the state, at all. Most public and for-profit institutions are probably safe. Publics have a clear line of authority and states are interested in the actions of for-profit institutions.

At greatest risk are community colleges (that are not funded by the state) and non-profits institutions. At a recent meeting, a representative of a religious college assured us that the state has no say over what they do. Well, that’s fine if you don’t want federal student aid. I also will refer you to a great book by Alan Contreras (former state regulator, but now of SARA) in which he details the legal basis behind the state determining who can or cannot issue degrees.

The others at risk will be those in states in which they have not created complaint processes for institutions within the state. I’m not sure every state had done this.

What Should You Do?

Pretend that your institution is completing the financial aid review forms. Can you identify the state entity that oversees you? Can you identify the state entity that would act on complaints from a student who is not satisfied with the outcome of your internal complaint process?

If you can answer “yes” to those two questions, you should be good to go.
If you answer “no” to either question, it’s time to figure out how to rectify that situation. There will probably be a process for the state to issue you a letter to explain why they are not yet in compliance.

Next, you should make sure that you are properly notifying ALL students (on-campus and online, “enrolled or prospective”) students about external complaint processes. In place since July 2011, Chapter 34, §668.43(b) requires an institution to provide “contact information for filing complaints with its accreditor and with its State approval or licensing entity and any other relevant State official or agency that would appropriately handle a student’s complaint.” Be sure that you have this information in a place on your website that is reasonably discoverable by someone looking for it. Pairing this contact information with a description of your college’s internal complaint process is a good practice. In previous posts, we clarified misconceptions on this regulation and answered questions as a result of that first posting.

Finally, get ready for those calls when people think they will lose aid if your institution is not approved in other states. I’m sure you have all the approvals you need anyway. After all, it’s the law.

Russ

Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu
Twitter: wcet_info and RussPoulin

Photo credit: https://www.flickr.com/photos/kenyee/278775281/

Complaint Process, Distance Education, Regulation, State Authorization, Title IV, U.S. Department of Education

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DEAC Announces Peer Review Process for Non-traditional Distance Ed Providers

By Russ Poulin

April 16, 2015

1 Comment

How do students judge the quality of distance education courses? The Distance Education Accrediting Commission’s (DEAC) new quality review process helps students to make that evaluation.

Traditional colleges have accreditation. Accrediting agencies traditionally provide peer-review evaluations to (according to the U.S. Department of Education) “ensure that education provided by institutions of higher education meets acceptable levels of quality.” However, there are a growing number of entities offering distance education courses that are not “institutions of higher education.”

Last Friday, DEAC announced its new Approved Quality Curriculum (AQC). This new service uses a standard rubric to peer-review non-institutional “providers” of distance education. StraighterLine and Sophia are the first “providers” to be recognized as achieving AQC status for their online courses.

This is a major step in erasing one of the major delineators between traditional credit-bearing institutions and their non-credit counterparts.

What it is the Approved Quality Curriculum?

The Distance Education Accrediting Commission (formerly the Distance Education and Training Council) is a federally-recognized accrediting agency. Even though they are approved by the Department of Education and the Council on Higher Education Accreditation (CHEA), the “national” accrediting agencies are viewed by some as a distant relative to the regional accrediting agencies. Despite that perception, DEAC’s rigorous review methods are the equal of its regional cousins.

“In AQC, we are applying the hallmarks of our accreditation process and expertise in distance education in a constructive and meaningful way for all offerings of online learning, whether institutionally based or not,” said Leah Matthews, DEAC’s Executive Director. “When DEAC conducts an accreditation process, it reviews education quality all the way to the course level. We are implementing the aspects of our course review process, and we call it AQC reviewed curriculum. Earning an AQC status means that StraighterLine and Sophia have met the same quality expectations for their courses that DEAC implements when it reviews courses as part of an accreditation review.”

Photo of Leah Matthews — Leah Matthews, Executive Director, Distance Education Accrediting Commission

Matthews credits the leadership of her board in seeking innovative quality assurance processes. Creating the AQC rubric took nearly a year of long and hard work according to Matthews. The process included input from institutions accredited by other accrediting agencies and from providers who might wish to participate in AQC.

According to Matthews, DEAC is careful to separate AQC from full-fledged accreditation since this process is not approved by the Department of Education or CHEA. Consumers were mostly left to their own devices to evaluate course quality. AQC’s helps fill that void.

Perceptions on AQC from a “Provider”

WCET member StraighterLine provides low cost, online courses offered individually or on a subscription basis. It is one of the two providers to achieve the initial AQC recognition. CEO Burck Smith is a former member of WCET’s Executive Council, so I reached out to him to get his input on AQC.

“DEAC is to be congratulated for taking a leadership role in reviewing curricula and courses from providers outside of traditional higher education,” said Smith. “StraighterLine is honored to have had its courses validated and vetted by acknowledged leaders in quality online education provision.”

Smith said that StraighterLine has sought third-party reviews from other sources and adds: “We have close to 90 colleges who have conducted their own individual evaluations of our courses and entered into articulation agreements with us.”

On his thoughts about accreditation, Smith said “At the highest level, accreditation provides three things 1) access to substantial taxpayer subsidies, 2) third party validation of quality for prospective students and other colleges, and 3) some degree of credit transferability. In exchange, you must offer entire degree programs and be subject to their review standards (which may make sense for a program, but don’t for stand-alone courses). For us, we believed that our price point was low enough that we could forego taxpayer subsidies, that articulation agreements with colleges would create credit transferability and that, eventually, enough 3rd party ‘Good Housekeeping Seals of Approval’ would equal or exceed accreditation as a stamp of quality.”

The Clamor Around Non-Credit Providers

You can probably blame it on the MOOC phenomenon, but there has been increased interest by policy-makers in the question of how non-credit educational opportunities fit into the educational puzzle. It also helped that the emergence of “providers” such as StraighterLine and Sophia have also raised serious questions about alternative paths of learning.

Some policy examples:

ACE was quick to get on the bandwagon of reviewing MOOCs for credit-worthiness, which is not accreditation but does provide course-level review that is used by many colleges in recognizing externally-offered learning for credit purposes.
Senator Lee (R-UT) recently reintroduced his proposed legislation (S649), which would allow each state to “establish an alternative accreditation system for the purpose of establishing institutions that provide postsecondary education and postsecondary education courses or programs as eligible for funding under title IV…” Oy! If you thought state authorization was bad, this could be a real headache.
The Council on Higher Education Accreditation has been trying to figure out a path to quality assurance for alternative providers and announced a Quality Platform Pilot. In partnerships with the Presidents’ Forum, they published the paper “Quality Assurance and Alternative Higher Education: A Policy Perspective” last year.
Inside Higher Ed recently published a nice summary of many of the issues around the review of alternative providers and competency-based education.

The reason that this issue is bubbling to the top is the expected reauthorization of the Higher Education Act of 1965, which covers the many regulations regarding higher education and federal financial aid. The big question is whether these alternative providers will be allowed into Title IV or other federal pots of funding. If so, what constraints will be place on them and do they really want to enter the world of regulatory oversight?

” We’re thrilled to be working with DEAC, it’s reflective of the semi-feverish activity going on to ‘own’ alternative credit review. CHEA announced a process,” said Burck Smith. “ACE has its Gates funded Alt-Credit project. Lamar Alexander issued a paper about it. David Bergeron and the New York billionaire are talking about it. The Department of Education is certainly interested. So, there’s a lot of activity which reflects the increasing inability to ignore the price differential of accredited v. unaccredited providers offering substantially similar offerings online.”

Leah Matthews says, “I see an increasing level of interest among higher education research groups and federal policy makers in alternative ways of assuring the quality of online learning that is offered outside of the domain of traditional institutions. I think it is incredibly important to continually visualize the future of online learning and think about how higher education is steadily transitioning to a more ‘learner-driven’ model.” Besides the nascent “direct assessment” models for federal financial aid, she feels there has been little innovation in federal financial aid since the Higher Education Act of 1965. We are still tied to the credit hour.

What does this mean for the future?

“Unaccredited providers are challenging a whole host of assumptions about higher education,” according to Smith. Chief among those is that “anyone can offer a college course. There’s nothing special about a course offered by a college or by some other provider — so long as the content, rigor and assessments are consistent (which they aren’t across all of higher ed). Therefore, online, accreditation is an arbitrary distinction that confers competitive advantages on one group of providers — usually much higher priced – than on the other equivalent set. As more students opt for lower priced offerings, colleges will have to acknowledge the validity of non-college courses.”

In looking to the future, Matthews she envisions a financial aid model that benchmarks on student achievement. As for the new “providers,” she sees the regulatory curiosity about them continue to grow. If they start receiving any federal money, they will face a new level of scrutiny that they have not previously encountered.

In my opinion, we are facing an evolving landscape that will no longer look like the traditional higher education structure that we experienced. For institutional leadership, those who do not recognize that the Earth is shifting beneath our feet do so at their own long-term peril. For the regulatory landscape, there needs to be a balance between consumer protection and innovation. Unfortunately, finding that Goldilocks “just right” point is tricky business.

Congratulations to DEAC and we look forward to following the progress of AQC and other effort regarding non-institutional “providers.”

Russ

Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu
Twitter: wcet_info and RussPoulin

Accreditation, Credentials, Distance Education, Financial Aid, Higher Education Act, Outcomes, Quality, Reauthorization, Regulation, Standards

Uncategorized

NANSLO Web-based Labs: Real Equipment, Real Data, Real People!

By Russ Poulin

April 7, 2015

Many pressures on higher education make the services of the North American Network of Science Labs Online (NANSLO) essential. These include growing enrollments in online courses while campus enrollments decline, the need to provide flexibility for nontraditional students, a growing demand for digital literacy, and a national emphasis on growing the number of STEM students, among others.

What is NANSLO?
The North American Network of Science Labs Online (NANSLO) is an alliance of cutting-edge science laboratories based at higher education institutions that provide students enrolled in science courses with opportunities to conduct their lab experiments on state-of-the-art science equipment using robotics, software, and video over the Internet. From any computer, students can log into one of the labs’ web interfaces and manipulate the controls on a microscope or other scientific equipment, participate in conversation with lab partners, ask for assistance from a knowledgeable lab technician in real time, and collect data and images for their science assignments. Through NANSLO, institutions can expand student access to STEM pathways, as they make it possible for students who cannot come to campus to complete lab activities online.

How Does it Work?
Through the NANSLO control panel, students:

CONNECT by computer to control the movement of high quality scientific equipment used to perform the assigned lab activities.“Very convenient and easy to use” Great Falls College Montana State University
Student, MT
DISCOVER AND EXPLORE. Students have the opportunity to think like a scientist – observing, interpreting, predicting, classifying, modeling, communicating, and drawing conclusions based on the data collected. Students watch their progress in real time on a webcam that displays what they are doing, and they gather real data to analyze and make predictions and draw conclusions.“It is much easier using an online microscope than even one by hand … You can
zoom/capture images, and do things you cannot otherwise do unless the
microscope is hooked up to a computer . . . ” Community College of Aurora Student, CO
COLLABORATE with lab partners nearby or around the world as each takes turns using the equipment. And, students get immediate help from the NANSLO lab techs when needed.“Great! makes me feel like I’m in an actual lab! Lamar Community College, CO
ENGAGE in active learning. As they work through the activities, students are actively performing their experiment, using their settings, experiencing their own observations, and collecting their own data.“This type of unique ‘hands on’ experience taps into parts of the brain that even
person-person labs miss.” Kenai Peninsula College University of Alaska Anchorage, AK

What is NANSLO’s Discipline Focus?
NANSLO has developed 27 lab activities in biology, chemistry, physics, and allied health that are openly licensed with Creative Commons BY attribution. These labs are easily integrated into course curriculum and include background information, pre-lab questions, and lab activities that can be performed online. Or, these labs can easily be customized to meet individual course requirements. A list of all NANSLO lab activities with access to the Word version is available for easy download. Over time, NANSLO expects to expand its collection within these initial disciplines and add others.

Who Participates in NANSLO?
The NANSLO network’s hub is based at the Western Interstate Commission for Higher Education (WICHE) in Boulder, CO. WICHE serves as the public’s primary resource for information about NANSLO, coordinates communication among the network’s lab partners, provides the centralized scheduling system, and oversees selected contracting and financial transaction services for the partners. Currently, the network includes three laboratories: the Colorado Community College System (CCCS) laboratory is located at Red Rocks Community College in Arvada in Colorado; the Great Falls College Montana State University (GFCMSU) is located in Great Falls, Montana; and North Island College (NIC) is located in Courtenay, British Columbia.

The CCCS laboratory began serving CCConline students in 2012 and continues to do so along with serving students from three Consortium for Healthcare Education Online (CHEO) community colleges in Colorado through a U.S. Department of Labor Trade Adjustment Assistance Community College and Career Training (TAACCCT) grant that established that initiative and provided funding for expanding NANSLO’s work. The NIC laboratory is primarily NANSLO’s development site but delivers lab activities to one CHEO community college in Alaska. NANSLO’s GFCMSU laboratory, established with funds from the TAACCCT grant, opened in late fall 2014 and serves four CHEO community colleges in Montana, South Dakota, and Wyoming.

How Do Students Access an Assigned Lab?
First, an institution or its faculty uses the centralized scheduling system to reserve a block of time for students to perform assigned NANSLO lab activities. When a reservation is made, a unique URL and PIN is generated. Faculty give their students this information, and students use it to access the scheduling system and select a day and time within the reserved block to complete the lab activity. Students also use that link or the student dashboard customized with information unique to them to access their NANSLO lab activities.

Once connected to the NANSLO lab, students have access to real scientific lab equipment that lets them:

Collect real time data and capture it electronically;
Experiment with different settings to see the impact on that data;
Capture high-resolution images to include in lab reports;
Engage in authentic instrumental experimentation;
Collaborate with classmates and lab personnel through teleconferencing; and
Gain skills that can be used in the future whether in science or other careers that require data collection, analysis and decision making, while gaining digital experience in remote web-based control.

Faculty can find out how their students are performing by logging into a dashboard customized for their use and selecting the lab activity of interest. The report generated assists them in determining student participation in the assigned lab activity.

Conclusion
Over the past year, students have been surveyed about their experience with NANSLO. Here are some comments:

“It was amazing to be able to sit in comfort of my own home and be able to work with this equipment. I believe this is the way of the future just because it is so fitting for people to be able to do this. Everyone in this world has busy lives and this makes it that much easier on people.” Kodiak College University of Alaska Anchorage Student, AK

“What a great resource, it was way easier to use and much cheaper than buying the microscope
for my class” Flathead Valley Community College Student, MT

“This was great and I can see enormous potential for online students. Thank you for the opportunity! Community College of Aurora, CO

“I think this was a great experience. I think it comes pretty close to the real thing, which is
great. :)” Arapahoe Community College, CO

In sum, NANSLO can provide real value to institutions by:

Delivering high-quality lab activities to students online in science courses requiring a lab component;
Providing students with access to real lab equipment allowing them to collect real data and think like real scientists;
Reducing the need to expend limited dollars on expanding labs on campus;
Providing students with an experience that can be applied to many professions; and
Addressing the need for flexibility in accessing and performing lab activities.

NANSLO’s future plans call for implementing a fee-for-service model so that other institutions can purchase NANSLO services for their students. It is also looking at cloud computing as a possible approach to expand capacity exponentially while further enhancing efficiencies.

If you would like more information about NANSLO go to www.wiche.edu/nanslo or contact Sue Schmidt at sschmidt@wiche.edu or 303-541-0220.

Sue Schmidt
NANSLO/CHEO Project Coordinator
WICHE
sschmidt@wiche.edu

Pat Shea
Director, Academic Leadership Initiatives
WICHE
pshea@wiche.edu

This product was funded by a grant awarded by the U.S. Department of Labor’s Employment and Training Administration. The product was created by the grantee and does not necessarily reflect the official position of the U.S. Department of Labor. The Department of Labor makes no guarantees, warranties, or assurances of any kind, express or implied, with respect to such information, including any information on linked sites and including, but not limited to, accuracy of the information or its completeness, timeliness, usefulness, adequacy, continued availability, or ownership.

Access, Distance Education, Lab Courses, STEM, WICHE

Uncategorized

What Can Happen If I Don’t Follow State Authorization Regulations?

By Russ Poulin

March 24, 2015

1 Comment

Those of us in WCET’s State Authorization Network (SAN) and in the State Authorization Reciprocity Agreement (NC-SARA) leadership often get asked the questions:

“Does anyone really enforce ‘state authorization’ in the U.S.?”
“Why don’t I read in the higher education news about colleges being fined for ‘state authorization’ violations?”

States are watching, regulating, and taking action. Before delving into that, let’s start with an example.

University Required to Issue Refund in “Unauthorized” State

Photo of a rat trap loaded for action with a piece of cheese on the trigger. — There could be consequences for violating state laws.

This recent action is told in the colorful verbiage of Alan Contreras. In a previous life Alan was the state regulator for Oregon. He now works for WCET SAN and NC-SARA.

A public university in the Midwest recently discovered what can happen in a relatively straightforward situation in which the institution failed to get authorization.

Institution X enrolled an online student in a state in which state authorization is required, but did not get that authorization. The student paid only a small part of the tuition due for a course and withdrew late in the term, past the standard withdrawal date. The student therefore owed the institution some money, and the institution requested payment. The student did not pay and the debt was assigned to a collection agency, as is the institution’s standard practice. When the student heard from the collection agency, the student wrote to the institution and said “this debt is uncollectable because you were operating illegally in my state.”

At this point the institution’s new compliance officer was served this rat sandwich by the affected department with a request for advice, and called WCET-SAN staff to discuss the issue. In our view, the institution was on shaky ground, so we advised the compliance officer to bring in the institution’s legal staff.

When the institution contacted the appropriate agency in the student’s state of residence, state officials there indicated that not only was the debt uncollectable, but all of the student’s tuition that had been collected had to be refunded in order to avoid formal action against the provider, which could have included a ban on operating in that state, as the institution had no authority to charge tuition to a resident of that state.

Yes, states really do take action, it just rarely appears in the headlines. Would you prefer mayonnaise or mustard with that sandwich?

All I can say is “Ouch”!

Photo of a line-up of motorcycle police and their motorcycles. — There are not state authorization motorcycle brigades, but there are those enforcing the laws.

What Usually Happens When an Institution is Found to be Out-of-Compliance?

Many states will contact the institution to inquire about an alleged infraction. They usually don’t start with a “cease and desist” letter, but I have heard of some colleges suddenly being surprised with such a notification. It’s a doubly unhappy day if the letter goes directly to your college’s president, as the president and public relations folks at your institution understand the damage of bad publicity…even if there is no official action, but word leaks out about not following laws.

The goal of the state regulatory agency is to protect students in the state by getting the institution into compliance. Often one of two paths is followed:

The institution decides to come into compliance and a process for doing so is negotiated between the institution and the state.
The institution decides to leave the state and an exit process is negotiated between the institution and the state.

Either way, at the end of the day the institution is following state law by either obtaining the correct approval(s) or leaving the state. Fines are a threat, but are rarely part of the final equation as both sides seek an amicable solution.

What About Student Actions?

Ah yes. Students can take matters into their own hands and sue the institution. This seems to happen most often in cases involving professional licensure. As you can imagine, a student will be quite upset after spending several years studying with you only to learn that their degree will be worthless in the state in which they are residing. A few years ago, I wrote about two such students who suddenly found that their program was unrecognized by the Board of Nursing in their home state. In one case, the institution sought authorization and made things right. In the other case, it was only under the threat of lawsuit from the student that the institution took action.

I heard a sad case last year in which a student moved to another state to attend face-to-face courses after being told that she could perform all of her practical fieldwork back in her home state. She quit her job and moved to the institution’s state. Once there, the non-profit institution told her that a new federal law had been passed and that she could not conduct her fieldwork in her home state. This was completely untrue. She quit the program before starting it, received a minor refund, and moved back to her home state. She did not wish to go after the institution and asked me not to reveal the identity of the institution. That college dodged a bullet. I was mad at the blatant disrespect and dishonesty demonstrated by this college.

Why Don’t I Read About These Actions?

Since everyone is seeking the best possible outcome, there is no reason for the regulator to embarrass the institution. The two parties often reach an understanding not to publicize the details of agreements resulting from findings of non-compliance.

This is all very boring to the press. No conflict. No story.

In Conclusion…

It often takes more time and effort to fix an unpleasant situation than to just do it right the first time.

The bigger compliance hammer will come if the Department of Education decides to bring back the state authorization regulation for distance education. The signs point to their planning to do so later this year. We will keep you updated on that process.

Meanwhile, states still expect you to be in compliance now.

Finally, life is easier if you treat students properly.

Thank you,

Russ

P.S. WCET’s State Authorization Network membership is now open. To keep updated on state authorization issues, come join us!

Russell Poulin
Director, Policy & Analysis
WCET (the WICHE Cooperative for Educational Technologies)
rpoulin@wiche.edu
Twitter: @russpoulin

If you like our work, join WCET!

Photo credits:
Rat trap: Morgue File.
Police: Morgue File.

Distance Education, Professional Licensure, Regulation, SARA, State Authorization, Title IV, U.S. Department of Education

Uncategorized

Federal Reg Updates: Teacher Prep, Ratings System, TEACH Act, & Net Neutrality

By Russ Poulin

February 4, 2015

Last week’s blog post looked forward to the likely reauthorization this year of The Higher Education Act, the “major law that authorizes the federal programs that support colleges and universities and their students, most significantly the federal student loan and grant programs.”

Meanwhile, there are several other laws and regulations that are currently in play. With the help of EDUCAUSE’s Jarret Cummings, we’ll update you on proposed new regulations of interest to the technology-mediated instruction community. Update include the teacher preparatory programs, the Postsecondary Institutional Ratings System, the new TEACH Act (focusing on accessibility requirements), and Net Neutrality.

Teacher Preparation Program Accountability

OLC, UPCEA, and WCET see many barriers to distance ed in proposed teacher prep regulations.

The Online Learning Consortium (OLC), University Professional and Continuing Education Association (UPCEA), and WCET jointly submitted a letter expressing our concerns with the proposed regulations for states to oversee teacher preparation programs. We especially focused on the concerns for teacher education programs offered at a distance. Our objections (which we initially identified in a post last December) included:

The burden on states and institutions to implement the proposed regulations is greatly underestimated. The measures for burden do not seem to account for the special issues faced by distance education programs enrolling students in multiple states.
Few distance education programs are included in reviews conducted by states. Distance education programs will need to comply with these new reporting requirements, which will differ with each state.
Since each state will have different measures for the same program, this could lead to confusion for consumers and possible discrimination against innovative programs.

We also provide five recommendations on how the Department of Education might address these concerns.

We at WCET express our gratitude to those at OLC, UPCEA, the President’s Forum, and the United States Distance Learning Association for co-signing the letter. We’re stronger together.

Postsecondary Institutional Ratings System

The Department of Education is also seeking comment on its proposed rating system that will be used for at the following purposes (taken from the College Ratings website):

“To help colleges and universities measure, benchmark, and improve across shared principles of access, affordability, and outcomes.
To provide better information about college value to students and families to support them as they search for select a college,
To generate reliable, useful data that policymakers and the public can use to hold America’s colleges and universities accountable for key performance measures. In the future this can be used to help align incentives for colleges to serve students from all backgrounds well by focusing on the shared principles of access, affordability, and outcomes; ensuring wise and effective use of $150 billion in financial aid.
In additional to federal efforts, and those of individual institutions, we believe the ratings system can help inform policy, accreditation and funding decisions by states education authorities, policies and practices of accreditors and others.”

While there is more details about what is being proposed, there is much work to be done. The document for comment includes several questions that they are seeking to answer.

The greatest short-term concern for those who serve non-traditional students is the IPEDS completion rate, which (until now) focused only on first-time, full-time students. Transfer students and those enrolling part-time were excluded from the counts. While those students are now being included, the first results from that inclusion will not be available until 2017 (see page 10). There’s one huge problem with this, version 1.0 of the ratings will be released prior to the 2015/15 school year (see page 2). Why are they releasing results prior to having accurate data on one of the most important outcomes measures?

We urge you to comment:

“The Department welcomes comments until February 17, 2015 on the approaches and specific questions outlined in this document either publicly through the comment section of the Department’s higher education blog or by email to collegefeedback@ed.gov”

TEACH Act Compromise Efforts Ongoing

Photo of Jarret Cummings. — EDUCAUSE’s Jarret Cummings updates us on the TEACH Act and Net Neutrality.

The National Federation of the Blind (NFB) and the Association of American Publishers (AAP) worked with members of Congress last year to introduce the Technology, Equality and Accessibility in College and Higher Education Act (TEACH Act). The bill proposed to foster the development of voluntary guidelines for “electronic instructional materials and related technologies.” Many higher education associations support this goal, believing that voluntary guidelines could help colleges and universities continue to improve in meeting the learning needs of students with disabilities. However, they have concerns that the bill as written would unintentionally hamper the use of technology to advance learning by all students, including those with disabilities. At a meeting last October, NFB and AAP agreed to work with the American Council on Education (ACE), EDUCAUSE, and others to develop a new legislative proposal for creating voluntary guidelines that would avoid the pitfalls of the previous bill. The groups have worked since then on a shared concept outline for a bill. A few outstanding issues remain, but once those are resolved, the participating groups will move to draft the compromise bill itself, with the goal of introducing it for the Higher Education Act reauthorization process set to start later this year

Network Neutrality Process Far From Over

As the Federal Communications Commission (FCC) neared the release of new network neutrality rules last fall, President Obama publicly advocated that the FCC reclassify commercial Internet access services as “telecommunications services” under Title II of the Communications Act of 1934. This would clearly establish the FCC’s authority to create network neutrality rules after federal courts had overturned previous efforts. However, it would carry with it a host of provisions developed over decades largely to cover “plain old telephone service” with utility-style regulation. Critics are concerned about the FCC’s ability to appropriately determine what and what not to apply from the Title II legacy. They believe that the FCC should use its more flexible authority under Section 706 of the Telecommunications Act of 1996 to craft rules without “stifling innovation with the heavy hand of government.”

Many believe that the President’s announcement has pushed the FCC to take the Title II route, which should become apparent when the FCC chairman shares draft rules with the rest of the Commission on Feb. 5. The commissioners will then vote on the proposed rules at a scheduled Feb. 26^th meeting, which FCC watchers believe will produce a 3-2, party-line vote for adoption. The telecommunications industry has made it very clear, though, that it will challenge Title II reclassification in court while also working with Congress to overturn any FCC action along those lines. The relevant committees in the House and Senate have already released a draft bill for discussion. It would create a new section of the Communications Act to establish network neutrality rules while preventing Title II regulation of ISPs. It is unclear whether Congress can pass a bill of this type, or whether such a bill could survive a presidential veto. So, it will likely be later this spring before we know what action, if any, Congress can take on network neutrality. And if the FCC’s rules clear that hurdle, we will have to wait for the courts to determine if the FCC finally has a formula that can withstand legal challenge as well.

Thank You, Stay Tuned, and Get Involved

Again, a big thank you to Jarret Cummings of EDUCAUSE for his great work on the TEACH Act (we’re indebted to him on this) and on Net Neutrality.

Keep watching for updates and get involved. The more comments, input, and influence that we can assert from multiple sources, the better off we will be.

Thank you for your participation.

Russ

Russell Poulin
Deputy Director, Research & Analysis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu
Twitter: wcet_info and RussPoulin

Photo credits: Smartboard by Jisc – https://www.flickr.com/photos/jiscimages/436456433

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