Update on the Five Types of State Authorization Regulations

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?The words "state authorization surrounded by all the state names.

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.

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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:

  1. What type of institution you are (public, private non-profit, private for-profit)?
  2. What activities does your institution perform the state in question?
  3. 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

Photo of Russ Poulin with baseball bat

Ready for baseball and regulatory season.


Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies

If you like our work, join WCET!

Highlights from #WCETSummit: #AdaptiveLearning in #HigherEd

As has become tradition, June 10th and 11th, a band of WCET’ers gathered to explore an emerging innovation in higher education – adaptive learning.  Following in the footsteps of our summits on big data and alternative credentials, this summit looked to answer what is adaptive learning and how do we apply it in a variety of institutional settings.  Today I bring you, with the help of our tweeps and the rest of the WCET team, some highlights of the summit.

Day 1

Peter Smith, chair of the WCET Executive Council and founding president, Open College @ Kaplan University, kicked us off with a few tidbits of wisdom to set the stage:

  • We’re all in this circle to figure out better ways to help students learn.
  • The companies participating in the Summit are here as partners, not as vendors.
  • Let’s figure out how to harness it, use it & make it productive – that which makes our life difficult contains the solution. There is no silver bullet, each institution has to figure out how this works in their own context.

Opening Plenary: The Science and Promise of Adaptive Learning

Contemporary adaptive learning products and technologies are built upon a growing body of science on student engagement, content mastery, and faculty recommitment to teaching.  Jim Thompson, president of CogBooks,  began by sharing the three main factors he sees as creating the perfect storm for adaptive learning adoption on a greater scale:

  1. Explosion in demand for higher education
  2. Infrastructure in place to allow for high fidelity education at low cost
  3. The adaptive technology itself has matured

Thompson also shared how brains work – that learning occurs through structure driven by time on task with attention & motivation, repetition and sequencing.  He asked us to perform a task that I’ll ask you to do now – try to quickly state the months of the year in alpha order instead of time order.  Harder than you might initially think because of the way our brains store information. The key of adaptive learning is discovering what students already know, how they have structured it and what is the best path forward to them.   The key to adaptive learning is personalization.

we don't know what they know.Judy Komar, Vice President of educational technology, Career Education Corporation, followed on this same vein noting that currently, we don’t know what our students don’t know.  A good way to think of adaptive learning is the swiss cheese effect – the technology allows us to identify gaps in knowledge mastery and fill those gaps that impede forward progress.  If the gap remains unfilled, the challenges remain.  Adaptive learning makes the students the decision makers in their learning and allows faculty to refocus on the art & science of teaching. This in turn allows them to spend less time grading and more time on interventions to move students forward.   For more of the great insights shared by these experts, view the video.

Institutional Case Studies: Using Adaptive Learning to Improve Outcomes

In 2013, the Bill & Melinda Gates Foundation launched its Adaptive Learning Market Acceleration Program (ALMAP) which funded institutional pilots to redesign and/or create new courses in partnership with one or more adaptive learning solution providers.   Rahim Rajan, senior program officer at Bill & Melinda Gates Foundation who leads the portfolio which includes the ALMAP, kicked off this panel by sharing the goals of the Foundation to improve lives gloabally, focusing in the U.S. on education.    Rajan pointed to the research done by Tyton Partners (1,2), which helped add some clarity to the different ways adaptive product pioneers were creating their adaptive learning experiences.  He also shared the work of John Hattie in Visual Learning that shares research based high impact pedagogical practice.

The institutions then got their opportunity to share some of the work they’ve been doing through ALMAP.  Here are a few highlights from the session, but for more detail be sure to watch the video:

  • Adaptive learning is a catalyst for instructors to re-engage with what they love – teaching.
  • You have to think holistically about adaptive learning – it will help you get the buy-in you need.
  • Students don’t know what to do with adaptive learning – they want the comfortable lecture. The key is communicating to students that you are still there for them.
  • Adaptive learning does not automate the faculty out of the equation; it gives faculty more latitude to focus on the students.
  • It takes a lot of academic courage to move forward with adaptive learning.
  • Adaptive learning is currently a craft – higher education must move it to the industrial level for it to truly make an impact.

For more on the ALMAP program and videos of those working in the field, check out our friend Phil Hill of e-Literate and the e-Literate TV series on personalized learning.

Small Group Conversations A

These small group conversations were not recorded, however, through the diligent work of the WCET team, we can provide you with a few highlights from each session.

lego wall kim phu

Adaptive Learning in Professional Education: Flipping the Lecture, Engage Students & See Results – Robert Hasel, associate dean, simulation, immersion and digital learning, College of Dental Medicine, Western University of Health Sciences.

  • Motivated learners remember more.
  • The “mapping” of the content is extremely important. Visualize a wall of legos. Each lego represents an explicit knowledge/competency.
  • Mapping the content also allows for keeping the content current – you can update what needs to be updated in a timely manner.

Institutional Models for Developing, Supporting, and Evaluating Adaptive Learning – David Pinkus, vp for Innovation, Western Governors University

  • Adaptive learning supports both the need to change previously held knowledge that is wrong and reinforce what was previously learned correctly.
  • Competency-based education + adaptive learning = Optimized Learning
  • Consider doing a pilot or proof of concept using micro-interventions rather than whole class reinventions.

How Adaptive Can (Has the Potential to) Increase Student Intrinsic Motivation to Persist – Kevin Bell, executive director, Curriculum Development and Deployment, College of Professional Studies, Northeastern University &

Ann Garnsey-Harter, executive director, Virtual Campus & Resource Development, Shoreline Community College

  • Adaptive learning is analogous to sports, i.e. basketball – practice, immediate feedback, etc. The key difference that the basketball player WANTS to get better at basketball.  How do we get someone to feel that passionate about algebra?
  • A truly adaptive course can be very time consuming for faculty. But prebuilt adaptive learning courses find some faculty resistance. Either way, some faculty will resist.
  • Intrinsic motivation=clear expectations, appropriate challenge, immediate and corrective feedback, sense of progress.
  • Ultimately it comes down to quality teaching. The tools allow faculty to be inspirational.

The Provost’s Perspective: Why Embark on an Adaptive Strategy?   Why Not? –  Connie Johnson, chief academic officer and provost, Colorado Technical University

  • Look at the data and give yourself permission to adjust and change in the process of implementing adaptive learning.
  • It’s about the academics, not the plan. Faculty are key to implementing adaptive learning.
  • It is more difficult to implement adaptive learning in subjects where students need original creativity.

Adaptive Learning Solutions:  A Town Hall with Some of Industry’s Key Providers

Vendor Town HallThis two-part session began with a moderated discussion among leaders of the major companies in the adaptive learning sector, including questions and comments from summit attendees.   Once the conversation concluded, attendees who had the unique opportunity to meet company CEOs, their team members, and some of their college and university partners to learn more about the products and services that support adaptive learning in higher education.   While those secondary conversations were not captured, you can watch the lively panel recording.  Some highlights include:

  • Adaptive Learning is an individualized personal mastery achievement platform.
  • Keep students in the zone of proximal learning. Not too easy, not too hard.
  • Adaptive courseware empowers and amplifies faculty to move from a one to many relationship towards a one to one relationship
  • The future of education will include open platforms, adaptive learning, and learning analytics.
  • Teaching is like gardening: you can’t will the plant to grow. You create the environment that enables the plant to grow.
  • We are all in a shift from education to learning, in a shift from input to output. Adaptive learning unlocks the creativity of faculty.

Small Group Conversations B

These small group conversations were not recorded, however, through the diligent work of the WCET team, we can provide you with a few highlights from each session.

Explore the Exciting Intersection of Adaptive Learning and Learning Analytics – Al Essa, vice president, Analytics and R&D, McGraw Hill Higher Education

  • Analytics systems (or any learning platform or infrastructure) must provide a “safe zone” for students to practice, to fail, to learn.
  • Know your audience!
  • Steps for institutions: identify the need; identify the partner/vendor; collaborate on more research on adaptive, effective interventions, etc.

Adaptive Courseware Options:  Before Selection, Understand Your Implementation Requirements – Dale Johnson, manager, Adaptive General Education Program, Arizona State University & Nick White, director, Competency Based Learning Solutions, Capella University

  • Content curation and course configuration are big factors in the choice of adaptive learning provider. The hardest part is the ‘black box’ – is their algorithm smarter than mine?
  • Content development is an art. Faculty need to have a clear-headed conversation about content development.
  • Look for existing relationships – don’t be a pioneer.
  • The stories matter. Get your elevator pitch. Build on early wins.

What Do Students and Faculty Say About Experiences With Adaptive Learning Courses? –  Tom Cavanagh, associate vice president, Distributed Learning, University of Central Florida

  • Students feel they are spending their time valuably.
  • Adaptive learning implementation ROI: as students are retained at significant levels the tool pays for itself.
  • Building the adaptive learning map takes time and resources.

What Does Success Look Like?  What are the Key Outcome Measures to Consider when Evaluating the ROI? – Rahim Rajan, senior program officer, Postsecondary Success, Bill & Melinda Gates Foundation

  • During a time of increased scrutiny and reduced resources, instiutions need to be more nimble and adept.
  • Find efficient solutions to produce better outcomes.
  • Consider student outcomes (equity, completion, persistence, etc)
  • Consider budget factors (cost of product, course redesign, RIO, shelf life of the course material, support costs, faculty development)
  • Measure faculty satisfaction

Day 2

The Devil’s in the Details:  Policies, Structures, Business Models, and More

Lively even during their first cup of coffee, Tom Cavanagh, associate vice president, distributed learning, University of Central Florida led a group of dynamic experts through a guided conversation about the details that surround all aspects of adaptive learning.  Experts on the panel were Diane Auer Jones, president  & CEO,  AJsquared Consulting; Manoj Kulkarni, CEO, RealizeIT by CCKF; David Pinkus, vice president of innovation, Western Governors University; Karen Solomon, vice president for accreditation relations, Higher Learning Commission; Nick White, director, Competency Based Learning Solutions, Capella University.  These brief highlights do not do the energetic conversation justice, so don’t forget the video is available.

  • Is adaptive learning really new or is it just technology-enhanced old methodology? Is it revolutionary or evolutionary?
    • It’s revolutionary in how we define faculty autonomy & puts the student in the forefront of accountability. The technology is evolutionary.
    • It’s revolutionary because of the scale.
  • What are the myths and misconceptions about adaptive learning?
    • While adapting instruction to students’ needs is not new, tech gives faculty much more information and students more agency.
    • Retention is a multivariate problem not a univariate problem. Adaptive learning alone can’t fix that.
    • Elephant in the room is that adaptive learning is that it’s perceived as multiple forms of the same content.
    • Faculty misperception is that adaptive learning is either ‘spoon feeding’ our students or replacing faculty. It’s not human being versus machine learning.
  • How do we get faculty on board?
    • Faculty champions.
    • Good faculty will always jump in with both feet. And hopefully they’ll drag the bad faculty, the naysayers, along with them.
    • adaptivity resonates with teachers vested in student progress.
    • Eliminate faculty ‘friction points’ with adaptive learning.
    • There’s a communication problem because of the discussion of algorithms which seem like ‘black boxes’ and the robotization of life.
  • What’s the ROI?
    • Retention, retention, retention.
    • Data show that adaptive learning improved outcomes for especially women & mintorities so there’s an ethical obligation to provide it as an option for our students.
    • There’s also the external accountability factor adaptive learning can evidence.
    • It’s all about the Delta – the change in the learning. And the accountability for external constituents & for students.
    • In the absense of data, antecdote wins.
    • Constructing meaningful pilots, collecting data, and getting faculty to support these initiatives = administrative support.
  • How much does it cost?
    • We’re in start of the adoption curve & vendors are looking for partners, for ‘wins’ so it’s cheaper now than will be.
    • Start small. Fund it smartly. Build up to it as you see successes. Enterprise implementation will come later.
    • It’s an upfront investment, but you may see returns over the years.
    • Good onboarding is very important. It should be accessible and easily understood – like what game designers do for 1st time players.
  • Final question, what’s your 140 character, pithy tweetable piece of advice?
    • If you want to bring edu into this century it has to be science based diagnostic based edu.
    • How will peer reviewers be able to understand the quality of the work you’re doing with adaptive learning?
    • If you’re committed to strong outcomes, adaptive learning is a good commitment
    • adaptive learning is active learning and the data show active learning works best.
    • adaptive learning makes it possible for faculty to be the best teacher for each student

Summit group 15Small Group Conversations C

These small group conversations were not recorded, however, through the diligent work of the WCET team, we can provide you with a few highlights from each session.

Setting a Data Foundation for Adaptive Learning:  Understanding and Planning for How an Adaptive Initiative will Impact the Overall Data Ecosystem – Mike Sharkey, president, Blue Canary

  • Competencies need to have a consistent set. It’s especially good if you can define competencies by career.
    • How do students get their data out to resumes? LinkedIn?
  • Who owns the data, who has access to the data and are there standards for the data are all outlined in the contracts with your vendors, pay attention to those.
  • Plumbing alone gives you no value. It’s the things you attach to the plumbing that give you value (toilets, sinks, etc.). The same is true for the data pipeline. It’s what you do with the data that matters.
  • Hear it a lot…IT DEPENDS. Need to focus on the pain point for your institution.

Leveraging Adaptive Learning within Existing Competency-Based Initiatives – Kara Van Dam, vice provost, University of Maryland University College and Ryan Hively, senior account executive, VitalSource Technologies Inc.

  • Adaptive learning is a method not an algorithm, not a blackbox. It’s a sequence of learning events.
  • Mind maps help look at content and overlaps, look for patterns to help organically form the adaptive paths rather than a linear trajectory. Competencies need to be looked at at the program level view, not just the course level.
  • It’s important to consider what the tools can and cannot do. The adaptive learning tool is a means of serving up content, not a substitute for teaching. The tools can free good teachers to be great teachers.

Choosing an Adaptive Learning Partner (Criteria, Licenses, Open Content, and More.) – Dale Johnson, manager, Adaptive General Education Program, Arizona State University & David Pinkus, vp for Innovation, Western Governors University

  • When selecting a vendor consider: gating criteria; instructional design & andragogy; instructor & administrative access; the pacing & the polish.
  • Vendors should provide you with access to a sandbox to determine if their solution fits your needs.
  • Create a way for students to curate their own content.
  • Your slowest student is your benchmark for how much content you can include in adaptive learning courses.
  • Assessment is going more & more to interactive elements. If you can solve the puzzle, you’ve mastered the content.
  • Overheard in #wcetsummit session – I don’t understand gaming, but I understand the look on my granddaughter’s face when she plays.

Post WCET Summit:  What Are Your Next Steps?   What More Do You Need to Know? – Judy Komar, vice president of educational technology, Career Education Corporation

  • If you have knowledge gaps, you can use adaptive learning anywhere in academia –> undergrad and beyond.
  • Adaptive learning is not always faster. Acceleration is the glam & glitz of marketing, still have to help students persist.
  • Pilot not just to determine if we use adaptive learning or not. Pilot means calibrate! Calibrate the faculty, system, and curriculum!
  • An integrated model to adaptive learning should identify programs/courses that will improve student success overall.
  • Always go back to looking at YOUR institution, your goals, your students. It will be different depending on your situation.

Adaptive Learning is Ready as an Applied Innovation – Are You Ready?

Mike Abbiatti and Peter Smith led us on a guided discussion for the last session of the day to answer 3 final questions – what are the characteristics of successful adaptive learning? Does adaptive learning work? And what 5 things do you need to have for deployment?  You can see the more candid version in the video but here are the crowdsourced answers from the closing session.

The top 10 characteristics of successful adaptive learning are:

  1. Efficiency of getting to objectives. Still the same ultimate goals, AL is just a method to integrate with the current teaching and learning methodology.
  2. Individualized/personalized.
  3. Scalable.
  4. Clarity– data and elements within the system and sharing of data.
  5. Cost effective.
  6. Responsive design.
  7. Basic ed-critical thinking
  8. Measurable outcomes
  9. Motivating- students and faculty
  10. Promoting student success.

 Does Adaptive Learning Work?

  1. Yes, across the student profile and faculty (medical/dental). “Game changer”
  2. Yes, faculty have more time for higher level thinking and at the student level (gen ed. Freshman)
  3. Yes, i.e. Abe Lincoln
  4. Yes, data informs decision making (corp perspective)
  5. Yes, but important to look at the theory and the implementation.
  6. Yes, analytics help faculty and students.
  7. Yes, statistically it helps marginalized students.
  8. Yes, but…cost of entry and ROI.

What 5 Things Do You Need to Have for Deployment?

  1. Effective Faculty Development.
  2. Senior leadership buy-in.
  3. Leadership that is not afraid of risk.
  4. Faculty champions.
  5. Resources/$$$.

santa fe signWe all left Santa Fe invigorated at the future possibilities that adaptive learning holds for higher education.  Resources from the summit are available on our website and WCET has made a commitment to continuing this conversation at our 27th Annual Meeting in Denver November 11-13, as well as through our blogs, social media, members-only discussion list and research.  We welcome those who were there to add anything we missed and those who weren’t able to make it to Santa Fe to join in the continued conversation.


Cali Morrison

Communications Manager, WCET

Follow us on Twitter: WCET|Personal


Photo Credit: Test: Lego Wall by Kim Phu

Santa Fe Photos by: Cali Morrison

Implementing a CBE Program: Lessons Learned from Community Colleges

“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.Photo of students wearing mortar boards at graduation.

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!


Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies

If you like our work, join WCET!

Credit for graduate photo: Morgue File

Four Recommendations for the Higher Ed Act Reauthorization

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.

US-Capital-by-Stephen-MelkisethianThe 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.


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):OneinEight

  • 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].


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.


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.


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.


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.


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.The words "state authorization surrounded by all the state names.

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.


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.


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.

Photo of Russ Poulin with baseball bat


Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies

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.

Ensuring Quality in Alternative Higher Education: Quality Matters’ Perspectives

Today we learn with Deb Adair, Managing Director and Chief Planning Officer, Quality Matters and Julie Porosky Hamlin, Executive Director, MarylandOnline; Member, Quality Matters Board of Directors their perspective on quality assurance for alternative higher education.  Thank you Deb and Julie for lending your many years of experience in assuring the quality online education to the continuing discussion of alternative higher education.

In the fall of 2013, the Presidents’ Forum (operating out of Excelsior College) and the Council for Higher Education Accreditation (CHEA) created a Commission on Quality Assurance and Alternative Higher Education.  They invited 26 individuals to discuss, over a three-month period, the idea of a quality review for the growing number of non-institutional providers of (largely online) courses.  In August of 2014, they published a paper, Quality Assurance and Alternative Higher Education: A Policy Perspective.

The group identified six questions for further inquiry.   Quality Matters (QM) did not participate in the discussion and we would like to contribute perspectives from our 10+ years in the field of quality assurance for online education.  Up to now, the QM rubrics and peer review process for certification of online quality have focused on the course level, but a program-level certification will be launched this year.

It’s a priority for us to be sure QM meets the needs of alternative providers; fits our tools and processes to their teaching and learning formats; and includes the voices of their representatives in our QA—quality assurance—community.

We’ve organized our thoughts around the six questions.

Would a Review of Alternative Providers Provide a Viable Public Service?

Q: Would a quality review process for alternative providers of postsecondary education offer effective documentation of quality and credibility to the public, including students, policy makers, and employers, providing a useful and viable public service?

A: Effective documentation must be a goal, perhaps the most important goal, of a quality review process that would serve the needs of alternative providers and provide QA for the consumers of their educational products.  Consider how useful it would be if we had a set of format-agnostic quality benchmarks that enable all stakeholders to compare courses offered by non-institutional providers with those offered by academic institutions. For that matter, comparisons within these sectors would be enabled as well. Using comparative data, students would be able to make informed choices, and policy makers would be provided with a common understanding of what constitutes a threshold of quality.

A common definition of online course quality would also enhance the transcript review process used now by academic institutions to accept and assign credit for courses from other providers.  It would offer academic institutions an efficient way to move beyond a review of course content and instructor credentials and to include other factors known to be important to student success.

We at QM have seen the benefits of creating such a threshold for quality and a process for benchmarking across institutions. Very often, the QM course review process and certification have been instrumental in intra-institutional direction setting and collaboration across units.

Many inter-institutional academic collaborations also rely on the QM standards and course reviews to support course-sharing initiatives.  In fact, the fastest-growing segment of QM subscribers are those participating as systems of institutions.  Currently, more than 60% of all subscribers do so as part of a consortium or system of institutions. We expect that the large number of QM subscribers who have invested significant time and effort to ensure the quality of their own courses will advocate for similar standards to be required of “credit-intended” courses offered by competing non-traditional providers.

What About a Cost-Benefit Analysis of a Quality Review Process?

Q: Would a preliminary cost-benefit analysis of a model quality review be informative? If so, how might this be done?

A: Once agreement is reached on the factors to be included in such a review, we can compare different review models already in existence to better understand the tradeoffs to be considered in understanding costs and benefits.  There is the traditional model of higher education accreditation, with significant expense in both time and money for on-site review.  The affordances offered by online education, the format utilized by a majority of alternative education providers, support a more cost-effective process of online, rather than on-site, review.  We offer Quality Matters’ approach as one model used to ensure the quality of online course (and soon program) design.

A QM higher education Peer Review team is composed of three trained and certified online instructors, at least one of whom is a subject matter expert and at least one of whom is external to the institution hosting the review.  The team, chaired by a Master Reviewer who has additional training and experience, is charged with taking the student perspective, applying the 43 QM standards with guidance from the annotations for each, and writing recommendations for improvement.

Recruiting, screening, and training the “talent” for conducting quality reviews is a challenge in itself.  QM has had more than a decade to figure it out, and we’re still fine-tuning and continuously seeking improvements.  Our online database contains more than 4,000 Peer Reviewers and Master Reviewers from across the country, and now internationally. A review typically takes three to six weeks for the first assessment and report; however, faculty/course developers have a total of 20 weeks to get through the review, including, if needed, time to make the recommended course improvements.  QM can and does manage these reviews for a fee; however, institutions may self-manage these reviews with proper training and certified reviewers.

As a result of a QM review, which is open and collegial, the faculty/course developer receives a report with improvement recommendations as well as certification of the course.  Using the Rubric and experience from benchmarking reviews, many institutions are now routinely training faculty and designing their online courses to fit the standards, an approach that prepares the courses for a successful review.  In these ways, institutions have been able to manage the time and dollar expense of course-level quality assurance.

Are You Planning to Pilot the Proposed Quality Review Process?

Q: Would development of an experimental model provide a means to demonstrate and test a workable quality review process? What might that model look like?

As obvious as it may sound, an effective quality review process must be anchored by assumptions about what constitute quality and those assumptions must be codified or captured in what we most often call “standards.”  Perhaps somewhat less obvious is that the standards themselves must have a clearcut focus or target to support consistent application.

The QM Standards, as an example, are focused on supporting student success.  QM has identified factors that are “important,” “very important,” and “essential” to student success.  The QM certification mark is intended to ensure:

  • a course is coherent and aligned with the course and module learning objectives:
  • that the purpose of the course, course components, and their relationships is made clear to students;
  • that the course is easy to use–in navigation, technology, and setting and communicating expectations– ensuring intra-course mechanics and extra-course requirements are not a barrier to learning;
  • that the course is built to engage learners and promote active learning;
  • that the content and assessment support the appropriate levels of learning;
  • that the learner is guided to technological, academic, and student support; and
  • that the course is accessible to all learners.

How did we come up with this particular set of standards?  Our flagship Rubric for Higher Education is now in its fifth edition, a clue that the standards have evolved.  Through a widely participative and in some ways messy process, QM standards are developed and regularly updated from a ongoing review of the research literature on student learning (see QM Research Library); from evidence-based practices; from analyses of review outcomes for the last 10 years; and from a large and growing community of practitioners actively engaged in using the standards.

QM’s mantra is continuous improvement, and our review process aligns with the quality assurances practices adopted in industry and other sectors with which education interacts. QM’s core elements are clear standards of quality for course and program design, training on the standards for faculty serving as course reviewers, and a review process focused on continuous improvement.

QM’s emphasis on continuous improvement is suggested in Figure 1, a back-of-napkin graphic that dates to QM’s earliest days as a grant project funded by the U.S. Department of Education.

Figure 1: QM Course Review Process

QM peer review process

What About Competencies and Student Outcomes?

Q: Inasmuch as the offerings of many alternative providers are designed to enable the student to master or demonstrate specific knowledge or skills, would a quality focus that measured competence (student outcomes) be a productive approach?

A: The ability to determine quality in a competency-based approach to education is as important for traditional academic institutions developing competency models as it is for alternative providers.

QM has been actively following the activities and research surrounding the competency-based education (CBE) movement. Our initial response is demonstrated in the Fifth Edition of the QM Higher Education Rubric, which includes guidance for evaluating competency-based learning. Much more work is needed to understand and guide approaches to CBE quality. QM looks forward to participating in the QA effort through collaborative initiatives to survey the field of CBE and identify the issues that need to be addressed through policy and practice.

Would It Lead to Alternative Providers Qualifying for Federal Student Financial Aid?

Q: Would an external quality review process for alternative providers offer a potential pathway for these organizations to qualify to participate in federal student financial aid programs, if such an opportunity were available?

A: Postsecondary education now includes more teaching-learning formats (MOOCs, CBE, adaptive learning, gamification) than it did just a few years ago, formats that are being embraced and experimented with by even the most traditional institutions, and credentials themselves are undergoing a rapid evolution.  External quality review, with its assurance of objectivity, could be an important component in a trend already begun.  The recent granting of financial aid for students earning degrees in CBE programs at collegiate institutions suggests the federal government in the near future may consider supporting other alternative formats from alternative providers.

How Would QM’s Work Lead to Greater Acceptance by Traditional Higher Ed?

Q: How would greater cooperation or adoption of some form of third-party verification or certification of standards of practice shared among organizations that review courses or student learning for credit improve wider understanding, acceptance, and utilization of the work of these organizations by colleges and universities?

A: This question asks, in part, how to broker a deal between external organizations that have developed principles addressing educational quality (QM, ACE, OLC are examples) and the colleges and universities that must be convinced these principles and the processes for applying them are sound: sound enough to warrant entering into a college transcript a “course” or other package of learning from an alternative provider. For quality assurance of alternative education to be effective, all parties must agree on standards and buy in to an evaluation process.

QM was developed as an answer to the need for inter-institutional quality assurance in online learning for a consortium of higher education institutions. Participating institutions had worked out how to run a seat-sharing program to allow students to enroll in one another’s courses, but the problem remained to convince stakeholders that students would be receiving an equivalent quality learning experience regardless of where they took their course. A common metric, one that is valid, consistently and rigorously applied, and collaboratively developed, was the answer that worked for the consortium, and later for other consortia around the country.

In Conclusion

We at QM are excited about the new educational options brought by alternative providers and excited to participate in a broadened and inclusive conversation about quality.


Deb Adair headshotDeb Adair,
Managing Director and Chief Planning Officer,
Quality Matters






Julie-Porosky-HamlinJulie Porosky Hamlin,
Executive Director, MarylandOnline
Member, Quality Matters Board of Directors


CCCOnline Finds Success in Six-week Intensive Courses

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 LogoCCCOnline 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?

6 week pass rates were comparable to 10 or 15 week coursesFor 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.
Photo of Terry Reeves.

Terry Reeves
Dean of Academic Instruction
Colorado Community Colleges Online

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

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.


Russell PoulinPhoto of Russ Poulin with a bat.
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
Twitter:  wcet_info and RussPoulin

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

Defining a New Model of Education: What Do Coding Bootcamps Mean for Higher Ed?

David Clinefelter, Chief Academic Officer at the Learning House,  joins us on the Frontiers blog today to share a partnership that is bringing college credit to coding bootcamps, helping students gain real world skills and credit towards a college credential at the same time. Thanks, David!

Innovation is the name of the game in higher education recently, and the federal government is getting in on the act. The Obama administration has made improving access to education, increasing the number of high school and college graduates, and promoting skills for a 21st century workforce a priority. While not the only factor, this commitment has helped to drive the growth of a new form of learning called coding bootcamps. Taking their nomenclature from the intensive training new recruits into the armed forces go through, coding bootcamps are intended to provide short term (eight to 14 weeks), immersive (all day, every day) programs that train people to be software developers (coders).

A National Commitment to Change

Coding bootcamp in actionIn early March, President Obama announced his Tech Hire initiative, which aims to help people acquire the practical skills they need for employment in “well-paying” technology jobs, such as software developers and coders. The initiative is encouraging both traditional colleges and universities as well as non-traditional providers to consider how they can better serve their population by enabling them to acquire relevant job skills for an evolving economy.

According to the White House, there are 500,000 open tech jobs, and not enough workers to fill this demand. These jobs are not concentrated only in tech hubs like San Francisco, but rather, are in cities across the country. Every city and region needs more coders.  To help meet this need, the Tech Hire initiative is trying to bring together public and private investment dollars, as well as encourage new, faster models of skill acquisition, such as coding bootcamps.

As part of the Tech Hire initiative, the federal government is investing $100 million to train and connect workers to good jobs in technology and related fields. Private companies, such as LinkedIn and Capitol One, are committing to aid the program.

Of those non-traditional models of education, coding bootcamps appear to be one of the most promising.

Technology Goes Local

code Louisville logoNot only is there a national commitment to increasing tech skills, but also local initiatives as well. Code Louisville, for example, is a coalition of government agencies and private enterprise developed to train people in Louisville, Kentucky, for the jobs of tomorrow.

“It’s kind of this vicious cycle,” said Rider Rodriguez, one of the co-founders of Code Louisville, in an interview with WFPL. “We don’t have a lot of software developers here because we don’t have a lot of software developers growing up. You don’t run into a lot of people who have those skills and do those jobs.”

Defining A New Model of Vocational Education

The appeal of bootcamps is simple: in some short, defined period of time (typically eight to 14 weeks), students will gain relevant skills that will enable them to find a well-paying job. Although currently bootcamps are focused on teaching programming languages, it is possible that in the future, they will be offered in disciplines such as marketing or finance.

Many bootcamps boast exceptional job placement rates for graduates; the Software Craftsmanship Guild (SWCG), for example, has a 96 percent placement rate.

“Bootcamps offer a unique opportunity to serve a distinct population,” said Eric Wise, founder and Chief Academic Officer of the Software Craftsmanship Guild. “Because they are so short, intensive, and skills-based, they appeal to highly motivated, talented people who don’t want or need to commit to a four-year degree, but who do want to make a change in their career and their life.”

How Do Bootcamps Work?: A Case Study

Learning House, a provider of online education solutions, was intrigued by the potential of coding bootcamps, but also realized the academic potential this model had. When Learning House began to consider offering bootcamps, most of the providers in the space were small, for-profit companies that were focused primarily on job placement as an outcome. Learning House imagined more.

“Bootcamps provide a terrific introduction to coding, giving students a solid foundation in core principles of software development,” said Dr. David Clinefelter, Chief Academic Officer of Learning House. “But we also know the value of the four-year degree. We felt that by partnering with an accredited, not-for-profit institution, we could expand the potential of bootcamps.”

Learning House turned to one of its partner institutions, Concordia University, St. Paul, for help in launching this innovative program. Using curriculum and expertise developed by SWCG, Learning House and Concordia were able to develop a coding bootcamp in the St. Paul area. Not only did the course teach the fundamentals of .NET to students, but it also offered college credit to students who graduated from the program.  The credits count toward the University’s BS in Computer Science, and students are eligible for financial aid if they commit to continuing in the computer science degree program after completing the bootcamp.

“Working with Learning House and the Software Craftsmanship Guild allowed us to offer students in Minnesota an immersive experience that prepares them not only for the jobs of today, but also for the industries of tomorrow,” said Eric LaMott, Senior Vice President and Chief Operating Officer at Concordia University, St. Paul. “The development of this program supports our goal of being responsive to the needs of today’s students and relevant to the skills employers seek.”

Getting Started

Developing a bootcamp program is, in some ways, both easier and more difficult than launching a new traditional program.

“We were able to rely on the experience SWCG brought to the table, which was an immense help,” said Todd Zipper, President and Chief Executive Officer of Learning House. “But there were a lot of operational logistics that also needed to be figured out, and figured out quickly.”

Concordia University provided the classroom for the coding bootcamp, administrative services such as financial aid, and most importantly, academic oversight.  The Learning House provided marketing, enrollment management, and recruited companies for an employer network.

Once the physical space was identified and set up, students were needed. The appeal of bootcamps, however, was evident from the marketing campaign. With minimal marketing – a mention on a local morning television show, some radio advertisements, and word of mouth – the inaugural bootcamp class was quickly filled.

“Students want a program that they know will lead to a positive result,” said Zipper. “Our Coding Bootcamp so clearly offered relevant, real-world skills, leading towards jobs with high salaries. And because we were partnered with a college that students recognized, they knew they could trust the quality of the education they were receiving. It was a win-win.”

Bootcamp Operation

CSP coding bootcamp logoThe Coding Bootcamp at Concordia is a 12-week, full-time, immersive program. From 9 a.m. to 4 p.m., students attend class in person and, through a mixture of lectures and practice, learn the fundamentals of either .NET or Java software languages.  The students are also expected to put in an additional 20 to 30 hours of work outside of the classroom per week.

Learning House has partnered with approximately a dozen local employers to help graduates find software development jobs. That employer network continues to grow, as demand from employers and IT recruiters increases.

For those students who wish to pursue their education, they are admitted into Concordia’s BS in Computer Science program, and will be given 12 college credits for completion of the bootcamp.

The Results

Even though the University and the Learning House were confident there was a need, the rapid success of the program still came as a surprise. Each session of coding bootcamp at Concordia has space for 12 to 16 students; before the first session launched, there was already a waiting list for the next session.

Such interest was not misplaced. Although the bootcamp demands a lot of time and energy, there was a 100% retention rate for the inaugural class.

“We asked a lot of our students,” said LaMott. “But we also worked to make sure everyone we admitted had the drive to succeed, and knew the expectations of both time and effort the bootcamp would require.”

Coding bootcamp gradsBefore admission into the bootcamp, students are required to complete an aptitude test and conduct an interview with an admissions counselor. They also completed approximately 60 hours of prework (online tutorials about coding basics.)  This helped ensure that all who were admitted had enough interest and ability in coding to stick with the intensive program. These admissions requirements not only helped the retention rates of the program, but also helped ensure a better classroom experience, since almost all students had the same level of expertise and passion for the subject.

Job placement rates are calculated after 90 days, so the final numbers are not in yet for the first bootcamp class. But within the first two weeks after completing the bootcamp, almost 70 percent of students have jobs as software developers. Several have chosen to continue into the BS in Computer Science program at Concordia.

The next bootcamp session also is filled, and the same retention and job placement rates are expected.

What the Future Holds

The success of the Concordia coding bootcamp confirmed Learning House’s commitment to bootcamps as a model of education for the future.  To that end, Learning House acquired SWCG and intends to offer coding bootcamps across the country. By the end of 2015, Learning House will be offering bootcamps in Akron, Ohio; Louisville, Kentucky; and St. Paul, Minneapolis. Learning House partnered with Code Louisville to help launch its Louisville bootcamp.

“Bootcamps are an extension of the core philosophy of Learning House that education should empower you to live the life you want. We could not be more pleased to be bringing the expertise of SWCG into the Learning House family, and we look forward to being on the forefront of this new education model.”

As more bootcamps are offered and more employers experience the value graduates can bring to needed, and hard to fill, roles, Learning House anticipates even more partnerships with major employers and universities in cities where bootcamps are offered. This new model of education – one where education and industry work together to provide students with relevant skills that prepare them to become drivers of the economy – offers immense possibility. Learning how to successfully become a part of this new approach to education will be critical to the success of institutions in the coming decades.


Dave Clinefelter headshotDavid Clinefelter
Chief Academic Officer
The Learning House

Breaking Bad: Improving College and University Teaching

Tony Bates has had a distinguished career promoting distance learning and open learning and content initiatives around the world.  Today Tony shares with us his latest book – an online, open textbook – as a resource for those teaching in our current digital age.  Thanks, Tony!

or: why I wrote an open online textbook for faculty.

I’ve just published an online, open textbook, Teaching in a Digital Age, aimed at faculty, instructors and teachers. As the title suggests, it’s a guide to teaching in an age when our students are immersed in technology. My aim is to give teachers, instructors  and faculty a foundational base of  theory and knowledge for their teaching, no matter what changes or pressures they face.

Why this book?

The main reason I wrote the book is because I couldn’t find anything similar for college and university faculty that provides in one place all that they need to know to teach well in today’s challenging environment. In particular, I wanted to provide some guidance on the following issues faced by all instructors today:

  • is the nature of knowledge changing, and how do different views on the nature of knowledge result in different approaches to teaching?
  • what is the science and research that can best help me in my teaching?
  • how do I decide whether my courses should be face-to-face, blended or fully online?
  • what methods of teaching are most effective for blended and online classes?
  • how do I make choices among all the available media, whether text, audio, video, computer, or social media, in order to benefit my students and my subject?
  • how do I maintain high quality in my teaching in a rapidly changing learning environment while managing my workload?
  • what are the real possibilities for teaching and learning using MOOCs, open educational resources and open textbooks?

What’s in the book?

Teaching in a Digital Age ImageThere are really six parts to the book.

The first chapter sets the stage for the rest of the book. It looks at the key changes that are forcing teachers and instructors to reconsider their goals and methods of teaching. In particular it identifies the key knowledge and skills that students need in a digital age.

Chapters 2 through 5 on epistemology and teaching methods address the more theoretical and methodological aspects of teaching and learning in a digital age. Chapter 2 covers different views on the nature of knowledge and how these understandings of knowledge influence theories of learning and methods of teaching. Chapters 3 and 4 analyze the strengths and weaknesses of different methods of teaching ranging from solely campus-based through blended to fully online. Chapter 5 looks at the strengths and weaknesses of MOOCs. These chapters form a theoretical foundation for what follows.

The focus of Chapters 6 through 8 is on how to choose and use different media and technologies in teaching, with a particular focus on the unique pedagogical characteristics of different media. Chapter 8 ends with a set of criteria and a model for making decisions about different media and technologies for teaching.

Chapter 9 addresses the question of how to determine what mode of delivery should be used: campus-based, blended or fully online. Chapter 10 examines the potentially disruptive implications of recent developments in open content, open publishing, open data and open research. This chapter above all is a messenger of the radical changes to come to education.

Chapter 11 and Appendix 1 take two different but complementary approaches to the issue of ensuring high quality teaching in a digital age. Chapter 11 suggests nine pragmatic steps for designing and delivering quality teaching in a highly digital teaching context. Appendix 1 looks at all the necessary components of a high quality learning environment.

The last chapter very briefly examines the policy and operational support needed from schools, colleges and universities to ensure relevant and high quality teaching in a digital age.

There are also ten ‘what if’ scenarios scattered throughout the book. The purpose of the scenarios is to stimulate imagination and thinking about both our current ‘blocks’ or barriers to change, and the real and exciting possibilities of teaching in the future.

Why a free, open textbook?

Many faculty are fiercely independent and many, indeed a majority, never go to formal faculty development sessions, so I wanted something really accessible, available at a click: no credit card payments, no workshop enrolment, just a resource available at any time, as and when instructors need it.

The book in fact can be used in many different ways:

  • as a resource for individual instructors
  • as a resource/prior reading for faculty development workshops
  • as a foundational reading for formal courses as part of a graduate program aimed at teachers and instructors
  • parts or sections can be used as resources for those wanting to take a different approach to faculty development.

It can be easily and continually updated, and indeed I’m hoping to build communities of practice around the book so that it remains current over time.

Lastly, I’m at the end of my career. I’ve already published eleven other books through commercial publishers, and I’ve had a wonderful career in educational technology over the last 40 years, so this is somewhat of a legacy project, pulling together all my experience into one place, and making it easily available to anyone who’s interested.

My main goal though is to make college and university teaching more effective, and move it from a broken, amateurish model to a more professional one. So please spread the word, and I hope you will find the book useful, too.

Tony Bates headshotDr. Tony Bates
President and CEO,
Tony Bates Associates Ltd

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

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.Logo for DEAC's Approved Quality Curriculum.

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.”


Photo of Russ Poulin with baseball bat

Ready for baseball and regulatory season.


Russell Poulin
Director, Policy & Analysis
WCET – WICHE Cooperative for Educational Technologies
Twitter:  wcet_info and RussPoulin


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