Ed Department Delays State Authorization Deadline – What Does that Mean?

On Tuesday, May 21, the U.S. Department of Education is officially releasing a new ‘Dear Colleague’ letter on state authorization.  I thought it might be helpful to put this new announcement into context.  But first, let me start with a reminder…

There Currently is No Federal Deadline for State Authorization for Distance Education
I often get asked, “so what date is the new federal deadline for institutions to be in compliance with state authorization regulations?”  The answer is that there is no deadline.

The Department of Education rolled back the clock on some state authorization rules.

After losing a court case and an appeal in federal court, the Department said last July that it will not enforce the vacated distance education regulation.  Therefore, there is no federal deadline.  Meanwhile, states expect that your institution comply with their regulations before you serve the first student in their jurisdiction.

So What State Authorization Deadline is the Department Delaying?
The distance education portion of the regulation was § 600.9(c).  There are two additional sections of the regulation (§ 600.9(a) and § 600.9(b)) that are not focused on distance education and remain in place.  These sections focus on what the state must do to authorize an institution, including having third-party complaint processes, identifying authorized institutions by name, and other requirements.

The states were supposed to address the new federal requirements by July 1, 2011.  Extensions were available to July 1 of this year.  A ‘Dear Colleague’ letter in January of this year reminded states of the deadline.

Much confusion ensued and there was concern by those at all types of institutions that their students might suddenly become ineligible for aid over some technical requirements.  Earlier this year, Dr. Sophia McArdle of the Department assured us that no student would lose aid because of this rule.  I know that Sophia has been working hard to help states meet this year’s deadline, but there was just too much that had to be done. I applaud Sophia and the Department for keeping their word and for issuing a new ‘Dear Colleague’ letter that extends the deadline for states to have their rules comply to July 1, 2014.

While happy for the extension, I was disappointed by a couple missed opportunities:

• Given the confusion on this issue, it was an opportunity to issue additional guidance.  There was initial guidance give in October 2010 (see Federal Register page 66858) when the regulation was first issued in 2010, but apparently that was insufficient or people could not find it. I’m hoping that the extension gives the Department time to issue more advice on what states should do and how they know if they are okay.
• The extension in the ‘Dear Colleague’ letter is actually issued to the institutions:  “In order for an institution that cannot demonstrate it meets the State authorization requirements under the Department’s regulations to receive an extension until July 1, 2014, to implement §600.9(a) and (b), the institution must obtain from the State an explanation of how an additional one-year extension will permit the State to modify its procedures to comply with amended §600.9.”  Legally, this might be the way it needs to be done, but the institution is only out-of-compliance due to state inaction.  Therefore, institutions must check a list (that does not exist) to assure that their state’s authorization agency meets federal requirements (which are confusing and open to interpretation) to determine whether it should obtain a letter from that agency explaining why a delay was needed.  Got it?  Only a handful of states and agencies will be affected, but I wish I could give you a list which ones those are.  It sure would have been nice to have an easier process.

What About State Authorization for Distance Education?
The Department apparently took the first steps to reinstate the vacated distance education rule.  In a Notice of Negotiated Rulemaking issued earlier this year, they are seeking comments on this issue.  You may recall that the original rule was vacated because they did not properly follow the commenting requirements.  Now they are.

I will be at the Hearing on this Negotiated Rulemaking that will be held in San Francisco on May 30.  I’ll let you know if anything interesting happens. Let me know if you will be there.

Russ

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

Support our work.  Join WCET!

 

Photo credit: Morgue File

Five more years of inaccessibility?

WCET welcomes Lauren McLarney of the National Federation of the Blind in giving us some recent history of and the next steps for proposed regulations regarding accessibility to educational technologies for those with disabilities.  Thank you Lauren.

I was in college a mere five years ago, but in that short period of time things have really changed.  The integration of technology into the educational sphere has fundamentally altered the teaching and learning process, and those changes – the arrival of digital instructional materials and the speed at which innovators come up with new and revolutionary things – are mostly for the good.

Technology has increased the accessibility divide
Before these changes, blind and other print-disabled students faced barriers to education and were segregated from mainstream students.  But now, curricular content that was once available only in textbooks and during lectures can be disseminated through electronic books, web content, digital library databases, advance software, and mobile applications. Compared to the print world, which excluded the print-disabled because it is inherently inaccessible, this intersection of technology and education creates opportunity to expand the circle of participation and allow universal access to mainstream products for all students, disabled or not. 

Instead, inaccessible technology has permeated the classroom causing print-disabled students to be segregated more so than ever before.  Rather than level the playing field, technology has created a whole slew of challenges to replace the traditional barriers to education faced by print disabled students.  What went wrong?

Commission reviews “accessible instructional materials” and makes recommendations
In 2008, the Higher Education Opportunity Act created the Advisory Committee on Accessible Instructional Materials in Postsecondary Education for Students with Disabilities (AIM Commission) to find out.  The AIM Commission was charged with talking to postsecondary students, university personnel, parents, and industry experts.  They looked at the status of accessible educational technology in postsecondary education, the reasons manufacturers have failed to embrace accessibility solutions for their products, and what institutions are doing to minimize the impact on print disabled students.

In June 2010, while the AIM Commission was doing its research, the Department of Justice (DOJ) and Department of Education (DOE) jointly issued a “Dear Colleague” letter reminding K-12 and postsecondary schools that deploying inaccessible technology was a violation of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.  In late 2011, the AIM Commission released its findings: “students with disabilities have experienced a variety of challenges, including blocked access to educational opportunities and matriculation failure resulting from inaccessible learning materials and/or their delivery systems,” and “…while there are a variety of emerging improved practices in the area of AIM, there is still persistent unmet need.”  The AIM Commission made eighteen recommendations (see EDUCAUSE summary) for fixing this – some calling for legislation, some targeting industry, and some directed at the DOE.

After years of inaction, action is required
Fast forward to 2013.  Not a single recommendation has been implemented.

That is two years since the report’s publication and five years since Congress first noticed a problem.  Five years of minimal progress.  Five years of disabled students being further segregated and challenged to finish their education without equal access.  In the interim, DOJ and DOE attempts at enforcement have failed to solve the problem.  Schools continue to embrace inaccessible technology at ever-growing speed.  When will schools stop retrofitting inaccessible products and start demanding full accessibility from the start?

The Technology, Education and Accessibility in College and Higher Education (TEACH) Act is our solution.  It calls on the Access Board to develop accessibility standards for electronic instructional materials and their delivery systems used in postsecondary education.  The DOJ will then issue regulations based on those standards, and enforce them as requirements under the ADA.  The standards will also apply to agencies of the Federal government under Section 508 of the Rehabilitation Act, should those agencies choose to purchase instructional materials.

TEACH is based on the first recommendation of the AIM Commission report, which calls on the Access Board to develop accessibility guidelines for instructional materials used in postsecondary education.  Second, TEACH does not create new liability for postsecondary institutions.  Rather, it provides clarity to the pre-existing mandate of equal access, which is already required under ADA and enforced by DOJ and DOE (as stated in the Dear Colleague).

If TEACH becomes law, all pre-existing flexibilities, statutory provisions, and implementing regulations under the ADA would still apply.  This means no new private right of action, no new penalties, and no new exemptions.  TEACH simply provides focus to a pre-existing legal obligation.  The objective of TEACH is to significantly increase the amount of accessible instructional materials in the marketplace and in the classroom without creating any new liabilities that are unfamiliar to postsecondary institutions or would inhibit innovation.

Help us in supporting students through the TEACH Act
Most postsecondary institutions want to provide their disabled students with equal access, but they aren’t sure what accessibility looks like and they claim there are not enough affordable options in the marketplace.  Manufacturers say they are willing to embrace accessibility solutions, but they do not see a large demand for it.  Institutions are blaming manufacturers; manufacturers are blaming institutions.

In the end, the burden falls on the student.

It has been that way for more than five years – it is time we take action.  The AIM Commission report gave us the data to know where to start, and the ADA provides the legal framework to get this done without reinventing the wheel.  TEACH will make it happen.

If your entity (institution, state agency, organization, corporation, etc.) would like to add your name to the growing list of those endorsing the TEACH Act, please contact me.  Once the bill is introduced, contact your U.S. Senator or Congressperson to obtain their support.  Meanwhile, take action on your own by making sure your technologies are accessible without waiting for TEACH.

Will you support this initiative – or will we ask disabled students to wait another five years?

Lauren McLarney
Government Affairs Specialist
National Federation of the Blind
LMcLarney@nfb.org

Reflections of Hurricane Sandy Six Months Later

Just days before Halloween in 2012, the residents of New Jersey faced the high winds, storm surge, and flooding from Hurricane Sandy.  We asked Sheri Prupis from NJEDge to give us an update on how New Jersey’s colleges and universities weathered the storm.  She also provides lessons learned for those of us who were lucky this time, but need to be prepared for the next emergency.

My days, like most of us, are filled with technology-related activities.  I am the Vice President for Academic and Community Engagement for New Jersey’s State Research & Education Network, NJEDge.Net.  Every day I am up to my eyeballs in networking, academic technologies, virtualization, consortium activities, and more.  Even on days when I am away, I check in several times to look at the status of my projects.  I believe in the work that my colleagues and I do, and I wouldn’t have it any other way.

In the aftermath of Hurricane Sandy, Richard Stockton College College helped by holding a food and clothing drive.

But who would have imagined that six months ago, on October 29, 2012 at 8:30pm, all of it would come to a screeching halt in New Jersey.  Hurricane Sandy hit and hit hard. All our priorities changed.

We knew for a week that the hurricane was coming.  NJEDge members (higher education institutes, K-12, research organizations) began to prepare.

Colleges and universities sent students home, closed their campuses, brought in extra fuel, and

worked with faculty on learning continuity strategies; all of this to keep learning, teaching, and research going, even if not on campus.

New Jersey was hit hard by Hurricane Sandy.  We sustained economic losses up to $300 billion.  Our higher education community by the shore was hit the hardest, but practically each institution had some malfunction.  Luckily for them it was not the NJEDge support system.

With NJEDge’s shared services, cloud services and remote hosting, most members kept their local networks up and their LMS’s running.  NJEDge’s statewide network, which provides Internet and Internet2 performed as designed and never went down. We remain robust.  We never lost connectivity, because redundancy was built in.  Internet access was not a problem, but power and communications on each campus was severely tested.

Lessons Learned
Several lessons were learned for the NJ Higher Education NJEDge.Net members.

Redundancy, Redundancy, Redundancy
Redundancy is not limited to networking:

• Application servers, authentication services, and web services need to be available in more than one location.
• Fuel resources have to be available from multiple vendors.
• Staff must be able to work in multiple modes.  Institutions must pay for air cards in mobile devices so that staff can perform vital tasks.
• Instruction must be available in multiple media (text, DVD, Internet, face-to-face).

Don’t Forget the People
Most important was the lesson to not forget people and their struggles:  so many of our members invited their local communities in as soon as the institution regained power.   Nearly half of the members made accommodations regarding exams, scheduling, and due dates – and still managed to end the semester on time.

Having the network running, having the LMS available simply isn’t enough.  Our faculty, staff, and students were worried about parents, children, and spouses.  They were looking for power, food, and places to live.  A few of them are still in temporary housing.  What was amazing was realizing that we had, at each of our institutions, a working community.  Using social media, our staff, faculty, and students were able to share information and resources and help one another.

The single most important role that NJEDge and our members had was providing a communications channel between individuals looking for resources of all kinds.

Next Steps
Social media was used at many New Jersey institutions to keep students informed of the situation on their campus.  While electricity was out and schools closed for days, smart phones kept communication afloat.

It is heartening to learn that faculty and students from many schools pitched in helping residents find temporary housing and to provide provisions and clothing.  Many of the residents along the shore lost everything.  Several schools created fund drives to help the victims of the storm and many used social media to get the word out and even to solicit contributions.

While we hope never to experience another hurricane as damaging as Sandy, we need to set up contingency measures.  New Jersey state agencies, research and hospital institutions, and the higher education community, along with K-12 districts represent a sizeable population to protect.  We welcome any examples of helpful technology protection colleagues can offer.

Sharing Our Stories
This blog posting is created so that we can share stories within the community, and derive contingency measures that can be put in place for the next super storm.

We reached out to our members asking for their experiences.  What follows are their stories.

Brookdale Community College
NJEDge and Brookdale Community College were in frequent contact working to keep mission-critical services up during the storm and its aftermath. In particular, Brookdale’s website was all-important conduit between college officials and our students, faculty, and staff.  Through the website we were disseminating information about when each campus would re-open and providing information about help and resources to members of the campus community affected by the storm. It was imperative that it remain available.

Our first call to NJEDge was Monday night at 11:30 PM during the worst part of the storm. All of us were at home without electricity when we received notice from our monitoring service that the college website was down. As damaging winds battered our homes, an NJEDge employee came to our aid to help orchestrate the changes needed to switch our website to Brookdale’s cloud-based backup site in Chicago.

The next day, the Office of Information Technology staff drove around downed trees and dangling power lines to arrive on campus, at which time we were able to find and correct a minor problem with our generator. As soon as we had brought our Lincroft data center back online, NJEDge assisted with DNS changes needed to restore service. Unfortunately, our return to the Internet was short lived, as twelve hours later our generator failed again, this time burning up an electrical part that was on backorder and unavailable anywhere in the country. Again, NJEDge quickly, and cheerfully, orchestrated the communication with Cogent which was needed to bring up our emergency site.

Although everyone was frustrated by the slow pace of electrical service restoration, many of in the college community remarked that they were pleased that Brookdale’s emergency website was available and up-to-date.

Fairleigh Dickinson University
Fairleigh Dickinson University (FDU) included in its preparation for Hurricane Sandy the rental of four large diesel generators and three 7,500 gallon trucks with diesel fuel to service the Student and Recreation Centers on each campus.  These generators were in addition to the permanently installed units that service the data centers and other select building life safety systems.  However, Hurricane Sandy prevented the normal delivery from FDU’s supplier as the supplier was flooded from the storm.  The University opted to not utilize the prearranged fuel as it had potentially been contaminated by brackish water during the flood.   In order to keep operations on keel, FDU arranged for local diesel suppliers to purchase out-of-state fuel.

The out-of-state supply was not ample to service the generator need.  As the Metropolitan Campus burns low sulfur diesel fuel in lieu of #2 fuel oil in its oil boilers, for emissions compliance, approximately 15,000 gallons was redeployed from the 20,000 gallon tank from one of the lecture halls to the generators on both campuses.

The College at Florham campus was out of power for nine days and the Metropolitan campus for seven days.  This was further complicated by students opting to stay on-campus instead of returning home.

FDU was well prepared for the storm and kept strategic buildings and services open with the generators and creative fueling. What we learned from the experience is to have multiple fuel sources with multiple depot availability.

Richard Stockton University of New Jersey
Stockton was closed Sunday-to-Tuesday during Super Storm Sandy. Monday was an instructional day. Tuesday was an advising day. Faculty had to make alternative plans for contacting their students. Some used telephone, email, Wimba Classroom, or set up appointments later in the week.

Approximately 200 students and employees were hard hit by the storm, many losing their homes. Assistance funds were set up with students and employees being very generous in their contributions.

From a technology standpoint, our data center is equipped with a UPS (uninterupted power supply) and generator. Even though the campus lost power our systems remained up throughout the storm. Power outages in the region were localized. Those who were not affected by the storm surge and power outages were able to continue with online work as usual. Student and faculty with the Blackboard Mobile Learn app were able to access the learning management system using smart phones and tablets.

Richard Stockton maintained some measures at working “against the tide.”

• Sending the residential students home was a good idea and helped ease the burden of feeding and housing the small number remaining.  Had we not sent the students home, it would have been necessary to feed 2,800 students for the duration of the storm.
• Since the storm Physical Plant has purchased 150 cots in the event a situation like this occurs again. This will alleviate the need for personnel to move mattresses to the Campus Center, which became very labor intensive.
• The need for additional emergency generator power became evident.  Although power was lost only for a short period of time, any longer would have become problematic.  The President has asked Administration and Finance to submit additional generator information and cost to him for consideration.

Georgian Court University
Classes were cancelled as soon as news of the magnitude of the storm was forecasted.  Georgian Court  (GCU) shut down its homepage, activated campus security by mass notification to students through all the emergency methods by texting, using the university’s Facebook and Twitter accounts as communication center.

When the campus lost power, our core system went down. Bringing it back up took a few hours, and this happened twice in the days immediately after Hurricane Sandy. Each time it went down, it took time to bring the servers back up in the right sequence, thus affecting a number of operations (e-mail, campus Internet access, ANGEL, the GCU portal). After the second loss of power, the university turned to its portable generators to power the bunker where our servers are kept.

For the IT staff, it was also difficult to determine how well our communications were getting through to members of the campus community.  We didn’t know what other systems (home phones, e-mail, cell phones) were available to our faculty, staff, and students.

With the hurricane directly overhead, the GCU campus lost power.  After four days of continual operation the Data Center generator ran out of Diesel fuel. That’s when the real IT work began. Once fuel arrived, the staff were tasked with bringing all services back up ASAP, which took over 6 hours. The next hurdle came three days later (one full week with no power to campus) when the generator started to spit and sputter requiring immediate maintenance. Luckily the IT staff had enough time to shut all the servers down properly. Shortly after shutdown, the “all clear” was given and the IT staff began the startup ritual for bringing services online. This time only the essential servers and services were brought up. These included Active Directory, Exchange, and SharePoint, each to support communications of staff, faculty, and students. Crucial data systems such as the File servers and ERP system were left in the safer off-state site until campus power was fully restored a few days later.

We saw definite benefits during the outage by having our main web site and student LMS hosted off-campus. For those that remained on-campus during the storm, they were challenged with outages to the IP surveillance system, the IP-based building card access system, and our small deployment of VOIP sets. It came down to power, whereas the GCU buildings with generators and utility power (there were a couple) had network connectivity, wireless, and telecommunications.

William Paterson University
William Patterson University survived the storm well. The damage was mostly from fallen trees. The University had well-defined disaster plans and a standing committee, which immediately went into action.

From a technical standpoint, the WPU Data Center ran on the natural gas generator power so all computer and network systems remained operational. One of our Internet circuits went down for a few hours affecting external telephone services to campus, but all Internet traffic routed to a secondary circuit did not lose data connectivity. We had a minor disruption of on-campus telephone service because an older generator supporting the telephone equipment did not start-up automatically when the power failed. Cell service was acceptable and campus radio communications were not disrupted, so there were no serious communication problems as a result of the loss of telephone service.

Our alert system, ConnectEd worked fine. as well as our web site postings and WPU e-mail announcements. Not all network switches and routers are on generators, so in those buildings, access to the campus network was unavailable until power was restored.  We have plans to have all network equipment on generators and move to complete VoIP which would provide better communications resiliency.

New Jersey Institute of Technology
In the final days of October, it became clear that the NJIT campus in Newark was in the path of Hurricane Sandy. For the IT team at NJIT, preparing for one of the most disruptive storms in recent history meant being ready for a loss of network connectivity, a prolonged power outage that could last days and even possible water damage to their data center environment. They decided that it was necessary to take proactive measures to ensure the availability of critical IT services. Deemed the most important piece to protect was the university’s web presence.

“The NJIT website is the face of the university and all of its college websites,” explained Kevin Byron, director of core systems for NJIT. “It is the primary communication tool among all members of the NJIT community. To have the website up [during a natural disaster like Sandy] was critical.”

The NJIT team decided that the best way to ensure the availability of the university’s website was to relocate their web presence. They sought a solution they could implement quickly with the storm approaching. They needed to act. And they needed to act soon.

Byron and his colleague, Matt Hoskins, senior enterprise architect for NJIT, reached out to NJEDge.Net, the statewide, member-focused provider of network and related services and a trusted strategic partner to the higher education community in New Jersey.

Critical Communication
On Monday, October 29, as Sandy reached the coast of New Jersey and moved inland, New Jersey Institute of Technology was prepared. Even with a loss of power in the NJIT data center environment, there was no lag, no dead air on their website. And they were able to maintain their web presence throughout the duration of the storm and its aftermath. This proved to make all the difference for NJIT students, faculty, and staff.

The NJIT campus lost power for approximately 22½ hours, beginning Monday night and continuing into Tuesday evening. And while power was restored, Newark and its surrounding areas were in such disarray from the storm that classes were cancelled for five days and the campus was closed until the morning of Saturday, November 3.

During the storm, NJIT staff were able to communicate campus-wide status updates via a text ribbon at the top of the NJIT webpage. These updates included class cancellations as well as services availability and restorations.

“That text ribbon had a 200 character maximum, but during the storm those were the most important 200 characters on the entire site,” Byron said.

The updates included a link to the NJIT SOS Blog, which contained more detail than could be communicated effectively through the text ribbon. NJIT SOS is a WordPress blog, so the infrastructure was logically distinct from the NJIT campus and available.

In the days following the power outage on campus, the number of hits on the NJIT SOS Blog skyrocketed. The ribbon and NJIT webpage were clearly important to a great number of people. Byron and Hoskins observed that most users who accessed the blog and website during the storm did so using smartphones.

A Sound Solution

On Friday, November 2, pleased with the restoration on campus, the NJIT website was returned to its primary location on the NJIT campus datacenter environment in Newark. All agreed that it was a successful undertaking and were pleased with the ease with which it was accomplished.

New Jersey Homeland Security
NJEDge played a part in keeping communication fluid between the Office of the Governor with national and state officials throughout Hurricane Sandy.  Through our virtual colocation and redundancy abilities, we were able to provide Vidyo videoconferencing telepresence to the different departments– the Office of Homeland Security and Preparedness, the New Jersey State Police, Regional Operations Intelligence Center, Office of Emergency Management and the National Guard – to be informed in real time.

We welcome any examples of ways to protect students, faculty, staff, and technology that colleagues can offer.

Sheri

Sheri Prupis
Vice President for Community and Academic Initiatives
NJEDge.Net
Sheri.Prupis@NJEDGE.NET

 

Copyrighted photo used with permission of Richard Stockton College of New Jersey:
http://www.flickr.com/photos/stockton_edu/8168506558/in/set-72157631964433643

 

Seeking Your Input on Fraud, State Authorization, and Other Regulatory Issues

In mid-April of this year, the U.S. Department of Education announced an “intention to establish a negotiated rulemaking committee to prepare proposed regulations for the Federal Student Aid programs…”  Through this process, the Department is visiting or revisiting several issues that are near and dear to the hearts of those of us in the distance education community:  financial aid fraud and state authorization.

It is also taking input on other issues, including: cash management of federal financial aid funds, state authorization for foreign locations of institutions located in a state, clock-to-credit hour conversion, gainful employment, and changes from the Violence Against Women Reauthorization Act of 2013.

This is the beginning of the process for the Department creating new regulations on these issues.  It is important that our voices be heard at the outset.  We wish to help inform and guide these discussions to dispel some of the misconceptions upon which some regulations were based in the past.

Seeking your input

By giving our feedback now, let’s hope to avoid some of the confusion from previous regulations.

On behalf of WCET and the WCET State Authorization Network, we will be submitting comments on the following issues.  I’d love your help, feedback, and suggestions on what should be recommended:

Financial aid fraud

The Department references a previous call for negotiated rulemaking that was issued in May 2012 that had a primary focus on the fraudulent use of financial aid funds.   While fraud comes in many forms, there is distrust of distance education and great worry about the opportunity for the misuse of funds for students who don’t appear on campus. Such concerns led to the proposal in last year’s federal budget from the Administration to lessen Pell eligibility for distance students.  While that proposal did not go forward, it is probably still on their list of possible solutions.

Briefly, here are some points that we would like to make in comments:

• Don’t confuse fraud (someone faking their identity purely to get money) with academic integrity (a known student cheating on a test to get a better grade).
• Don’t punish the innocent.  The Pell grant proposal was an example of a solution that would be equal to solving the problem of bank robberies by closing all the banks.
• Promote education of the types of suspicious activities that are common among fraudsters.  Sometimes faculty or other administrators can raise red flags that others would not see.
• Promote good practices in combating fraud, both in the administrative and academic sectors of the institution.  The more difficult it is for the fraudster to jump through administrative and academic hoops, the less inclined they are to commit fraud.
• Don’t look for a silver bullet.  It’s not there.

What else would you suggest?

State authorization for distance education

The regulation issued in 2010 was vacated by the federal courts ruling that the proper rulemaking process was not followed.  This is the first step in their following the rulemaking process and my guess is that this regulation is on its way back.  I’m NOT going to recommend that the federal government stay out of this issue because it is with us regardless of what they do.  Some comments that I would like to make:

• If you reissue this regulation, be sure that there is adequate time for institutions to comply and for states to respond.  Even though institutions have been repeatedly warned about this issue, a large number are still out-of-compliance.
• Repeat the Department’s strong support for reciprocity.  In the past, the Department has supported the notion of reciprocity several times, but some people still can’t hear it and previous support was based on the vacated regulation.
• Please provide clear guidance on several issues that remained unclear from the previous round with state authorization, such as:
  • how you will count if a student can receive 50% of a program in another state,
  • will consortia agreements suffice for reciprocity,
  • how do internships (and other experiential learning) fit into the authorization requirement,
  • will the current worries about “exemptions” for in-state institutions also apply to providers from other states, and
  • what is the penalty for non-compliance?

Some of these really get into the minutiae and I will expand in the final comments.

• As much as possible, rely on each state’s definition for authorization and don’t create new definitions to layer on top of those regulations.  For example, differences in regulations could lead an institution to being in compliance for federal purposes but not for state purposes.

What would you add?

State authorization for foreign locations of institutions located in a state

This one really surprised me and it is worded oddly.  I’ve confirmed that by “foreign” they are talking about institutions that have locations in other countries.  With the growth of such institutional ventures abroad, I can see that the federal government might be concerned about the quality control.  I’ve also learned that there are some institutions that are located in the U.S., but teach no students here.  They look like a U.S. institution, but no U.S. entity has approved them.  There’s great potential for defrauding foreign students.  I’m not sure how this fits in with federal financial aid, but we’ll learn more about it. My comments:

• Does this apply to distance education, as well as “locations?”  If so, what does that mean?
• Is this only for federal financial aid?

What are your thoughts?

Overall philosophy

I have one overall philosophy that I wish that regulators move toward adopting:

Regulations should not differentiate by mode of instruction unless the regulations are actually about the tools used in the mode of instruction.

Let’s stop differentiating aid based upon whether a student is on-campus or not.  We should focus on student outcomes.  Our future will see more technologies, more modes of instruction, greater mixes of face-to-face and distance, and a greater focus on competency-based instruction.  It is getting harder and harder to differentiate this modes of instruction as they all become intermingled, thus making the differentiation obsolete.

Stop worrying about the inputs.  The current definition of distance education includes many technologies.  Given the rapid change in technologies, any such list is out-of-date as soon as it is published.

Regulations should be in place when they are actually about the tools being used.  Institutions have been lax in assuring accessibility for the disabled.  It makes sense to assure that access is open to all.

Next Steps

Comments are due to the Department by the end of May.   You may submit your own comments.  To be contribute to WCET’s official response, supply comments below or send your thoughts directly to me at rpoulin@wiche.edu by Monday May 20.  There are also three opportunities to testify on these issues.  The dates and process to register to testify is in the announcement.

This feedback process is just the first step.  Later this year the will ask for nominees to be on a Negotiated Rulemaking Committee to consider specific regulatory language.   We will continue to follow these issues, actively participate, seek you input, provide comments, and suggest stronger action, if needed.

Your input makes our collective voice stronger, so thank you for sharing it!

Russ

Russell Poulin
Deputy Director
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

Support our work.  Join WCET!

Photo came from Morgue File: http://www.morguefile.com/archive/display/185087

Concerning Online Learning: Experience Matters

After I published my blog piece that analyzed the Community College Research Center’s (CCRC) new research on online students, Mac Adkins of Smarter Services contacted me about research based upon the experiences of institutions using their services.  Mac was invited to submit this guest blog, which presents outcomes that undergird some of  CCRC’s findings and some the support my suggested alternative interpretations.  You may wish to look at CCRC’s follow-up to the study and advice on “Creating an Effective Online Instructor Presence.”  I think they adopted some of the comments made about their original work. Thank you Mac for adding to the research discussion. — Russ Poulin, WCET

This guest blog post is a continuation of the thoughts shared by WCET’s Russell Poulin in February, 2013.  In that post, Russ responded to criticisms and observations of eLearning which were published in a New York Times editorial as well as a report by the Community College Research Center.

Russ stated, “The biggest takeaway that I took from the CCRC research is the need to make sure that students are prepared to succeed in an online course.”  This statement caught my attention as this has pretty much been my life’s work for the past decade.  Since 2002 we have measured the levels of online learning readiness from over two million students with our Learning Readiness Indicator.

In the section of Russ’s blog post titled “Students Adapting  to Online Learning”  Russ stated that when one first experiences online learning, the student who is new to online learning must “adapt” to this learning modality.  He added, “The vast majority of students spend the bulk of their education career without having taken an online course. It is an adjustment.”  I fully concur with this observation.

Each year we publish for free the National Student Readiness Report (pdf). The report presents aggregate data from over a half million students each year who have taken the assessment.  One of the demographic factors which we collect on the assessment is “How many prior online courses have you taken?”   Sometimes a student enrolling in school A has already taken several prior online courses at school B.  Most of the time, the new students have had little or no prior online learning experience.  In the annual Readiness Report, we compare the means of each of our scales across persons based on their prior experience in online learning.

You Can’t Beat Experience
One of the strongest findings of this section of the report is that when it comes to distance learning – experience matters.  Students who have taken five or more prior online courses had statistically significant higher means (random sample of 300) than students who had taken fewer online courses on the following subscales: Persistence, Procrastination, Time Management, Locus of Control, Technical Knowledge, and Help Seeking.   Students with this level of online learning experience also had statistically significant higher means in all six of the major scales measured by the assessment with the exception of reading and typing rate.

The greatest difference in means from students with no prior online course experience and those who had taken five or more courses continued to be in the area of technical knowledge. This indicates that with experience students can learn to use the technology required for online courses.

The take away for eLearning leaders is that we really need to hold the hands of students who are new to online learning.  If we can closely support them and help them persist past that second online course, then the learning curve for eLearning levels out.  This fact is perhaps a partial explanation of the higher dropout rates for new online students which was cited (albeit inappropriately) in the New York Times editorial.

I also concur with Russ when he stated, “The authors are off-base in suggesting that students be ‘screened’ out of an online class.”  Very few of the schools which use our readiness assessment use it for screening.  If they do so, then typically they recommend the student take the course through a hybrid or on-campus delivery system.  No schools use it as an admissions screening device.  Schools need students.  Schools also need students who will remain enrolled.

In the 2012 National Student Readiness Report, the majority (54%) of students reported that they had never taken an online course prior to taking the SmarterMeasure assessment. It is worthy of note that the percentage of students who have never taken an online course is decreasing. (see graph above:  2012 = 54%, 2011 = 55%, 2010 = 60%, 2009 = 65%) This is an indicator that eLearning is becoming a more common educational delivery system.  It is important to note that the CRCC study’s cohort  included “degree-seeking students who initially enrolled in one of Washington State’s 34 community or technical colleges during the fall term of 2004.”  The percentage of students who had never taken an online course was probably much higher nearly a decade ago.

Demographics and Online Learning
The CCRC study focused on certain demographic groups underperforming in online courses.  In the National Student Readiness Report, we also cross tabulate means of our scales across several demographic factors.  Aggregate data from over 690,000 online students who took the assessment over a twelve month period revealed that for the past four years in a row females have had statistically significant higher means in Individual Attributes, Academic Attributes, and Time Management.  Over that same four year period of time, males had higher means in Technical Knowledge.  Caucasians also had higher means in Technical Knowledge for four years in a row.

It is a fact that some learners are a better fit for online learning due to their attributes and skills.  But should that imply that they not take online courses?  As one of our client institutions recently stated, “You cannot change a tiger’s stripes, but you can teach that tiger to hunt in a different environment.”  Through well-developed orientation courses and other online student support services, we can equip students with no prior experience with the skills to learn online.

Dr. Daniel Golman, author of Emotional Intelligence, recently blogged about the topic  “It’s Modes, Not Personality Traits.”  He emphasized that persons tend to behave in different ways in different circumstances.  In our context, a person who is a habitual procrastinator about online course assignments may never procrastinate about other activities such as working out in a gym.  As educators it is beneficial in our communications with students to talk in terms of one’s traits in the mode of learning.

By assessing an individual’s attributes, attitudes, and skills for the context of  eLearning, both the individual and their school are better equipped to determine the level of readiness of a new online student so that the appropriate resources for support can be provided. 

Mac Adkins
President
SmarterServices.com
mac@SmarterServices.com

Highlights from the National Meeting on State Authorization Reciprocity

A national meeting on next steps in state reciprocity was held in Indianapolis on April 16 and 17.  The purpose of the event was to serve as an initial introduction to representatives from each state about next steps in reciprocity.

The session focused on the report:  Advancing Access through Regulatory Reform: Findings, Principles, and Recommendations for the State Authorization Reciprocity Agreement (SARA) that was recently released by the Commission on the Regulation on Postsecondary Distance Education.   The Commission, which is a committee formed by APLU (the land-grant universities) and the State Higher Education Executive Officers, built upon the work of previous efforts of the Presidents’ Forum/Council of State Governments and the regional higher education compacts.  You can see a short history of state authorization and the reciprocity efforts on our web page.

Sponsored by Lumina Foundation, the meeting attendees included representatives from 47 states.   Delaware, Hawaii, and New York were not represented.  While they did not send participants, we know that there was interest in the first two of those states in participating. Others in attendance to this invitational event included those who had involvement in shaping the reciprocity language.

Opening Remarks and Support

The report is meant to be a framework for reciprocity with additional provisions to be detailed in the final SARA wording.  The meeting started with several introductory sessions presenting the principles outlined in the report.

A letter was read from Molly Corbett Broad, president of the American Council on Education, lending her support to reciprocity.  Hal Plotkin of the U.S. Department of Education had the most memorable metaphor of the night, which you can ask me about later.  While the Department of Education cannot formally endorse the work, he brought a two-word message from the Secretary Arne Duncan and  Under Secretary Martha Kanter:  “thank you.”

Some Questions that Arose

If they can receive foundation support to begin the effort, the regional higher education compacts (Midwestern Higher Education Compact, New England Board of Higher Education, Southern Regional Education Board, and Western Interstate Commission for Higher Education) will be charged with jointly implementing the agreement in as seamless a way as possible.  Regional sessions were held to cover additional fine points of reciprocity and to gather comments and questions from participants.  There were many items on which there were agreement and many questions were raised.  David Longanecker, president of WICHE, highlighted a few in a final plenary session:

• Accreditation.  There is  still some angst about the efficacy of depending on accreditation for quality assurance.  David sees reciprocity as a way to give us all more license to work with the accrediting community.  Working together, we should be able to have more evidence to take to the accrediting agencies about any concerns.
• Fees.  The report was relatively silent on fees.  The current plan for fees includes:
  • State fees to institutions.  The state might decide to charge an institution for the process of authorizing it to participate in SARA.  States raised questions about their own ability to charge institutions (this might be currently prohibited in some states) and the reorganization of duties required.
  • Institutional fees to join SARA.  Institutions participating in SARA will be charged a yearly fee on a sliding scale based on overall institutional FTE:  $2,000 for those less than 2,500, $4,000 for those 2,501 – 10,000, and $6,000 for those more than 10,000 FTE.  Due to the current high variance in how “distance education” enrollments are counted, overall institutional FTE is the current proposed metric.
  • State fees to join SARA.  States in a regional compact will not be charged.  For those states and territories not in a compact (District of Columbia, New Jersey, New York, Pennsylvania, and Puerto Rico), they would be charged $50,000 to affiliate with a regional compact for this one purpose.  (UPDATED: 04/18/13 – Delaware is part of SREB, while Pennsylvania is not in a regional compact)
• Legislative and Regulatory Language.  States will need assistance with the proper language.  While the regional compacts can’t lobby, they plan to provide some help in crafting language and in connecting states to learn from each other both about legislative language and  in handling the fees issue raised earlier.
• Determination of Home State.  There are several examples of complex relationships and the details on those outliers needs to be considered.  It is clear that institutional shopping for a state will not be tolerated.
• Professional Accreditation.  There was a proposal to have more restrictions on education offered in fields of study in which licensure or other professional accreditation is required in a state.
• Metrics for Holding a State Accountable.  Clear metrics will need to be developed as to what a state reports.
• The Physical Presence Limit of 25% of Course Instruction.  More justification, details, and metrics were requested.

Again, these are all questions.  Some reflect items on which this is considerable work, but either additional details, subtle nuances, or more justification is needed.  A few of the items will need much more work.

Next Steps

Recordings of the meeting will be made available in the next few weeks.  When I receive the links, I will post them to the blog.  Watch for additional follow-up information from the Presidents’ Forum and the Commission.

The regional compacts are very optimistic about receiving grant support to move forward on this work.  Once they do, they will hire staff and hold regional meetings to discuss these issues.

Finally, A Note about Tone

While much of the meeting was very positive, there was significant regulator bashing during the meeting.  Some of those with regulatory roles let me know of their displeasure.

While there are regulations that are real head-scratchers, there is real purpose behind many of these regulations. We should not paint everyone charged with overseeing authorization in the states with the same brush.  They are charged with upholding their laws.  They are charged with protecting students.

Reciprocity is asking them to make significant changes in their work, to go out on a limb and trust others, and to accept the risk of those changes.  Since they will face much of the impact, the least the rest of us can do is respect them and listen to them.

Russ

Russell Poulin
Deputy Director, Research and Anaylsis
WCET – WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

Support our work!  Join WCET.

Navigating the Current State Authorization Kerfuffle for On-Campus Instruction

This week both the Chronicle of Higher Education and Inside Higher Ed have reported on a developing issue with the federal regulations on state authorization. From your emails to me, these stories have been a bit confusing and confounding to many of you.  Some people are worried about losing their federal financial aid for students. This gave me an opportunity to do my best to clarify the issue and relieve (I hope not heighten) your concerns.

Before getting into the details, let me start with two main points:

• The current focus on state authorization is not about distance education.
• The Department of Education does not intend for this current focus on state authorization to lead to students not getting aid.
  

  Institutions depend on the state agencies that authorize them to make them eligible for federal financial aid. If the Department of Education finds some of those agencies out-of-compliance, will their institutions find themselves in shallow financial aid water?

The current issue is related to the ‘Dear Colleague’ letter that was released by the U.S. Department of Education earlier this year.  At that time, I blogged that this issue is NOT about distance education.  That remains the case.  I talked to Sophia McArdle, the Department’s point person on authorization issues, recently and she reconfirmed that point with me.  In brief, the distance education section of the regulation (§ 600.9(c)) has been vacated by the federal courts and cannot be enforced unless the Department takes further action.  They have yet to do so.

If not about distance education, who does it cover?

It’s mostly about on-campus instruction.  The actions cited by the Chronicle and Insider Higher Ed are about federal regulations § 600.9(a) and (b), which cover what the state must do to be able to authorize institutions that are headquartered (my term, not theirs) or have a physical location in that state.  Among other requirements, the states must have third-party complaint processes and must identify authorized institutions by name.

States were expected to have their authorization processes in compliance with these regulations by July 1, 2011.  They could request two extensions, which means the final deadline is July 1, 2013.

With the final deadline approaching, the recent concerns being raised by the Department are aimed at some types of institutions over others.  From here it gets complex and I will not explore every possible option, but I will highlight the two broad categories into which the regulation divides institutions.  The following table provides the definitions of the two types of institutions and the approval processes that may or may not be used for that type of institution.  Note that in the column headings I provide the regulatory sections and my own titles for each category.

	Column A § 600.9(a)(1)(i) Public (and, Perhaps, other) institutions	Column B § 600.9(a)(1)(ii) Proprietary (and, Perhaps, Private) Institutions
Defining the type of institution	“established by name as an educational institution by a State through a charter, statute, constitutional provision, or other action issued by an appropriate State agency or State entity and is authorized to operate educational programs beyond secondary education…”	“established by a State on the basis of an authorization to conduct business in the State or to operate as a nonprofit charitable organization, but not established by name as an educational institution under paragraph (a)(1)(i) of this section.”
Allowable approval process	“complies with any applicable State approval or licensure requirements, except that the State may exempt the institution from any State approval or licensure requirements based on the institution’s accreditation by one or more accrediting agencies recognized by the Secretary or based upon the institution being in operation for at least 20 years.”	“may not be exempt from the State’s approval or licensure requirements based on accreditation, years in operation, or other comparable exemption.”

Public institutions receive more latitude in state approval processes

For the most part, Column A is aimed at public institutions. This is debatable as the phrase “or other action issued by an appropriate State agency or State entity” could cover a wide range of activities used by the state to recognize other institutions. In any case, I have yet to hear of an instance in which a public institution has been mentioned as having its authorization questioned under this regulation.

Proprietary (and perhaps, private) institutions need to take note

Column B definitely covers proprietary institutions and may cover some private institutions.  Any concerns that I have seen raised by the Department have been for the processes for approving these types of institutions.  But, I have not seen all of the concerns that they have raised.

What types of concerns have been raised?

The two main concerns that I have seen (there may be others) raised by the Department are:

• It appeared that some states were exempting institutions that the Department felt should have fallen in the Column B definition above.  Florida has been in the news about this, but I believe that they were able to show that there was more to their process than a simple exemption.  This is a problem with the regulation as it disallows several exemptions for institutions defined in Column B, but is silent on what additional authorization actions would suffice.
• Some states licensing procedures did not distinguish between secondary and postsecondary institutions.  The states needed to be more specific as to whether the institution was authorized for postsecondary education.

My advice

If you think your institution might be in Column B above, check the wording in the regulation and check the procedures of how you were authorized in your state.  If you have a concern, work with the authorizing agency in your state.  If there are sufficient concerns, have your authorizing agency contact Dr. Sophia McArdle at the Department of Education to ask for a review of their procedures.

VERY IMPORTANT:  Sophia is about six weeks behind in responding to these queries.  Let’s help her out, which will help you out.  Only the authorizing agency should contact her, not each institution. She’s trying to respond to each institution, but that is setting her way behind.  Also, make sure that the agency has done the research it can and has very specific questions to ask Sophia. Following these steps will expedite the process for everyone.

This is not about denying aid to your students

Finally, I’m returning to the second bullet in my opening.  Dr. McArdle assured me multiple times that the Department of Education does not intend for this current focus on state authorization to lead to students not getting aid.  You would not know that from reading the Chronicle or Inside Higher Ed articles.  Sophia assured me that she is more interested in getting state processes into compliance than in punishing institutions and students.  I believe her.   Could the Department have handled this better and provided clearer guidance?  Definitely.  It’s not time to panic, but authorizing agencies should take this seriously.

So what about distance education?

As you may recall, the federal courts vacated the regulation regarding the federal state authorization requirements for distance education.  The Department said that it will not enforce that regulation.  We should remember that the regulation was struck down on a technicality  and the Department could decide to reinstate it.  The decision on when (or if) to do so has been delayed due to the massive turnover in the postsecondary leadership at the Department.  As these decisions are made, WCET will keep you informed.

The bottom lines for distance education…

• I keep getting asked about the July 1, 2014 or July 1, 2013 federal deadlines for state authorization institutional compliance for distance education programs.  Since the distance education regulation was vacated, there is no regulation and, therefore, there IS NO DEADLINE.
• As was true before the Department got involved and continues to be true today, states expect you to follow their regulations prior to serving students in their state.

Watch for my coverage from the national meeting on state authorization reciprocity that will be held on April 16 & 17.

This keeps getting more fun, eh? And I got to use the word “kerfuffle”!!

ADDENDUM APRIL 6, 2013:  This post has sparked several conversations in the last day.  A couple points to clarify:

1. Column A v. Column B:  I may have been a bit too subtle in my classifications. There could be a public institution that is not in column A, but most are.  Alternatively, there are several private institutions that have state charters (especially older institutions when that was a common way of recognizing them) or others like Western Governors University that have special recognition in a state.  For your institution, be sure to read the language for federal regulations § 600.9(a) and (b) and carefully determine where your institution fits.
2. Proceed in All Haste in Getting Clarification from the Department of Education:  While Dr. McArdle is very clear that the Department is not interested in seeing institutions and students lose aid, it’s a bad idea to have your institution or students having any exposure at all on this issue.  If your authorizing agency is not sure that its rules are acceptable, it should request an opinion from the Department.  Alternatively, we need another extension or more clarification on the regulation as a whole.

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

Support our work.  Join WCET!

Photo credit:  Morgue File by ecerroni

CTDLC: Collaborating to Offer eTutoring

In this Frontiers blog, we welcome back the 2007 WCET Outstanding Work (WOW) Award winning eTutoring program from the Connecticut Distance Learning Consortium.  A long running program by any standards, this WOW Award winner has continued to grow and improve over the past six years.  Speaking of WOW Awards, don’t forget to nominate your or a colleague’s outstanding work in applying an innovative, technology-based solution to a challenging educational need.  Nominations are open until April 22  to all WCET members.

When the Connecticut Distance Learning Consortium was created back in 1998, it’s doubtful our founders imagined we would someday be providers of online tutoring to over 130 institutions of higher education across North America. But that’s exactly where we find ourselves today.

The Origins of the eTutoring Collaborative Idea

As a membership organization, created by our state’s legislature to help Connecticut’s colleges and universities develop and deliver high quality online courses to its students, the notion of collaboration between and among colleges and universities was at the core of our efforts from the start. In the process of one of these projects, the eTutoring program and platform emerged. Diane Goldsmith, Director of Learning, Assessment and Online Education at the University of Rhode Island, and Executive Director Emerita of CTDLC, tells the story:

 “It was 2000 and the colleges and universities in Connecticut were beginning to offer online classes, however, no one was thinking about how to provide academic support to those students.  I was new to CTDLC, but thought that a collaboration might provide an answer even though I didn’t really know how.  So I wrote a grant with 7 institutions and we were funded to build collaborative online student support services, despite having no real idea how to do that in a state where each institution saw itself as its own universe.  We began to focus on tutoring and listened to myriads of concerns, from a blanket, “you can’t tutor online,” to the specific, “all our tutors have to be familiar with the textbook for each class.”  Then one day, a Distance Learning Director said, “But if my institution provides a writing tutor and yours a math tutor, we can cover more subjects, serve more students, and provide more tutoring hours than if we each go it alone.”  

Expanding the Model to Other States…and Another Country

That was the break-through that led to a larger conversation and a firm commitment to the collaborative process, where a plan to share tutors from participating institutions across one common online schedule and meeting place developed into our eTutoring initiative. Today, utilizing the tools in our synchronous and asynchronous eTutoring.org platform, we manage the Northeast eTutoring Consortium supporting 36 colleges and universities in six states, while providing the technology, hosting, and support to two other consortia: the Washington State Board for Community and Technical College’s Western eTutoring Consortium, currently serving 41 colleges and universities in 6 states, and the Ohio eTutoring Collaborative, supported by the Ohio Board of Regents and open to all colleges and universities in the state.

Just recently, the eTutoring program has expanded into Canada as the province of British Columbia through BCcampus has adopted the platform in support of their WriteAway program. To ensure national and provincial privacy, Simon Fraser University – a member of BCCampus, has partnered with us to host the eTutoring platform in their Vancouver location. This hosting arrangement may enable other Canadian institutions to utilize the eTutoring program while keeping Canadian student data on Canadian soil.

The Benefits of Collaboration and Community

While it’s gratifying to see our collaborative model and platform reach such a broad audience, the most satisfying aspect of this work by far has been the collaborative nature of our practice, which brings together learning center and elearning experts to design all aspects of service delivery and to assure excellence in program quality.  One of our Northeast Advisory Council members captures this notion best:

 “… the ongoing sharing of ideas and resources contributes to even greater benefits. What you have done is create a forum for the sharing of new ideas in teaching and learning and, remarkably, a platform for the realization and testing of these ideas.” Greg Fallon, Assistant Dean for Learning Resources, Passaic County Community College.

So as we’ve grown from a local consortium to a community of consortia, we continue to seek and identify opportunities to facilitate the sharing of ideas and expertise crossing institutional, state, and consortial boundaries, a process further enriched by the Ohio Board of Regent’s bold eTutoring expansion.  Ohio eTutoring Coordinator, Karen D. Boyd, shares their story:

“When Ohio’s institutions of higher education looked for an online tutoring platform, the group looked for affordability, flexibility, and autonomy. What we discovered in Connecticut Distance Learning Consortium’s eTutoring program were all three components. Working with the group, we identified five pilot schools in Fall 2009, and grew to 15 schools, then 20, and now 40 schools participate in the Ohio eTutoring Collaborative. By establishing the collaborative, we saved institutions start-up, training, and monitoring costs – funds that have been recycled into institutions’ tutoring programs. 

Building a platform that addressed Ohio’s students’ needs and specific learning styles rather than making a canned approach fit has been the most rewarding aspect of the experience. While CTDLC established protocols and initial training modules, it encouraged us to meet with campus coordinators and tutors to build on that foundation. Our group meets virtually three times a year, and face-to-face annually to discuss changes, additions and best practices. What sets eTutoring apart from vendor-style platforms is that educators, administrators, tutors and students are stakeholders who influence how to respond to today’s student needs affordably and effectively.”

Much of the eTutoring program’s expansion is a direct result of being actively involved in the WCET community. Professional relationships fostered over the years have led to the creation of these tutoring collaborations in Ohio, Washington, and British Columbia as well as the use of our platform to support local online tutoring at institutions like the University of Hawaii.

We are always looking for new partners and new suggestions for improving or growing our eTutoring community.  We think this approach to solving shared challenges makes compelling sense and we hope it to see it applied in new arenas.

Kevin Corcoran
Executive Director, CTDLC
kcorcoran@ctdlc.org

____________________________________________________________________________________________________________

Carolyn Rogers
Director of Academic Services, CTDLC
crogers@ctdlc.org

Competency-Based Learning at Northern Arizona University (& New USDOE Rules)

We had planned this blog to run today, but did not know that the U.S. Department of Education would choose March 19 to release its new “Dear Colleague” letter on ”Applying for Title IV Eligibility for Direct Assessment (Competency-Based) Programs.”  In the letter, the Department says: “This letter provides guidance to institutions that wish to have direct assessment (competency-based) programs considered for title IV, Higher Education Act (HEA) program eligibility. The letter outlines how institutions can have competency-based programs approved under the current regulations on direct assessment programs.” 

While you are absorbing that new guidance, we welcome Fred Hurst as our guest blogger.  He shares with us the vision and lessons learned in Northern Arizona University’s pursuit of “personalized learning” through competency-based programs.

Fred Hurst, Northern Arizona University

We continue to move forward to implement our Personalized Learning initiative this spring.  For those of you who may not be familiar with it, Northern Arizona University’s Personalized Learning enables motivated students to earn a high quality degree more efficiently and at a lower cost by customizing coursework to fit individual learning styles and previously acquired knowledge.

What is Personalized Learning?

Our education system, from Kindergarten through college, is designed like an assembly line – every student is treated the same.  The problem is that every student is different.  For example, even in Kindergarten, some children can read, others can’t read at all.  The gaps in ability only get worse over time and they vary for every student.  In high school, I didn’t understand grammar but I was a math whiz.

Using technology to create self-paced online programs allows education to be personalized to each student in a way that would be prohibitively expensive in our current faculty-led model.  Competency-based education can ensure that each student gains true competency, not just squeaking by with a “D.”  Research tells us that most students are turned off to learning by middle school.  Competency-based education can bring back the joy of learning to many students.

We designed our Personalized Learning program from the ground up.  We threw out all our current approaches to pedagogy, student support and business processes and reinvented them using the latest techniques and technologies.  Students have multiple instructional options to help them master the material: video lectures and documentaries, simulations, games, and even textbooks.  Each student has a faculty mentor to tutor them to ensure they master the material. Additionally, we want to utilize adaptive learning powered by big data to steer students to the learning options – and developmental and supplemental materials – which will most efficiently allow them to be successful.

Personalized Learning is based on a subscription model.  Like Netflix, the student pays for time, not by the credit hour.  The flat $2,500 cost per six months is all-inclusive for all the courses the student can master – no extra charges for textbooks/materials, IT or climbing walls.  Can you imagine going on Amazon.com and having a long list of the costs that make up the price of an item you want to buy:  $14 for manufacturing, $10 shipping from China to the U.S., $4 for marketing, etc.?  The student may start any day of the year and their personalized semester is six months long, regardless of when they start.

Implementation Challenges We Faced

Sounds great, huh?  Well, being a change agent isn’t always easy.  We had originally hoped to implement Personalized Learning on January 2^nd of this year.  A number of factors have slowed us down including campus discussion, technology glitches and regulatory requirements.

Discussions with campus offices and departments about why and how Personalized Learning can work are ongoing and not without some controversy.  This was expected, and, in the end, we have the support to move forward.

Technological issues include how do we fit an innovative program with 365 semesters per year (366 in leap years) into a student information system that is designed for three semesters per year?  How do you provide federal financial aid to students when they are not enrolled in a specific number of courses in a semester?  If a student is in the middle of a course when their subscription/semester ends, how do you assess their progress for financial aid and how do you transcript their work?  These sorts of questions are difficult to answer and even more difficult to implement in a rigid student information system.

The North Central Association’s Higher Learning Commission has a pilot program in place to assess five institutions including Northern Arizona University to authorize the offering of competency-based programs.  The first programs will be considered for approval in May.  When approved by our accrediting body, Northern Arizona University will apply to the U.S. Department of Education for authorization to offer Title IV federal financial aid.  As of this writing, the first and only institution to apply, Southern New Hampshire University, believes their approval is imminent.

Northern Arizona University is in the process of final quality assurance on the degree programs – Computer Information Technology, Small Business Administration, and Liberal Arts.  The business processes and the user interface will be in place in April.  We will implement this spring after the Higher Learning Commission approves us to offer the three degree programs.  Personalized Learning students will not have federal financial aid available until later in the year when it is anticipated that the Department of Education will authorize us to offer it.

I close with the following quote by Victor Hugo, “An invasion of armies can be resisted, but not an idea whose time has come.”

Fred Hurst
Senior Vice President of Extended Campuses
Northern Arizona University
Fred.Hurst@nau.edu

The Reason THIS EDUdotcom May Not Be As Different From Last Time As You Think

If there was ever any doubt that we are in the midst of a new dot.com boom for education, that doubt was removed at last week’s SXSWEDU. The event brought entrepreneurs and educators to Austin, Texas for four days of panels and a competition for education start-ups. I had the great fun of participating in a panel discussion on “Are Courses a Commodity?” with Myk Garn, Mickey Revenaugh and Michael Horn. Vanessa Dennen and I helped Curt Bonk rehearse his “cage match” answers while sharing beers and ribs at one of the Cengage social events. I enjoyed hearing Bill Gates speak to the crowd about his vision for a transformed education system. It was definitely an interesting mix of energies.

Ellen Wagner, Executive Director of WCET

Gotta say, not all of it felt all that good. The Chronicle of Higher Education covered the event with a headline that explicitly named the tensions between entrepreneurs and educators: ”At South by Southwest Education Event, Tensions Divide Entrepreneurs and Educators.”

While I was there, I kept hearing that THIS dot.com is different because it’s about education, and because the tech is better and data will inform us and investors are smarter and the market is ready and there are business plans and people aren’t just throwing exuberant ideas at the wall and hoping that something sticks.

Really?

I have to say that the confident assurances that this educational technology boom is different just didn’t make me feel any less skeptical. Because in the same way that there are some who really DO believes that MOOCs are the birth of online learning, it is clear that there is an entire generation of investors and entrepreneurs who really DO seem to believe that the ideas thrown against the wall of the 1990s are somehow less legitimate than some of the ideas that are currently being thrown against the wall today.

So let me tell you why this particular new EDU.dot.com isn’t as different as visionaries and investors would have you believe.

Ready?

It’s because no matter how new your tech is or how great the idea is, or how impressive the possibilities are, or the circumstances, or the bandwidth, or the platform, or the operating system we won’t figure out how to crack the code on transformation until we change the most important part of the equation. And that is the human factor. Eventually it comes down to people being ready to embrace the change. The ability to ride out the hype cycle and get oneself to a true plateau of productivity will all come down to the degree we can induce people to change their ways, completely rethink their practices, and help them figure out how to use new tools toys, apps, and the like to deliver on their promises.

The excitement around innovative technology futures for teaching and learning has energized educational researchers to think broadly and deeply about the possibilities they represent.  The venture capital communities’ recognition that education may be ready for its “Internet moment” has also generated massive interest in developing promising ideas for products with commercial consideration.

Between these two exciting arenas of exploration live equally important opportunities for transformation that come from practice-focused solutions contributing to demonstrable improvements in student engagement, faculty performance, and institutional accountability.

People. We’ve got to get ready, too.

Ellen Wagner
Executive Director, WCET

This is a version of a blog post that originally appeared on Ellen’s eLearning Roadtrip blog.