ACCJC: DE on the Front Burner

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>>: I have 12 o'clock on my dial here. So, we're going to go ahead and get started. Welcome
everybody. Thanks for participating in today's presentation we are looking at distance education
on the front burner-new regulations, new challenges and accreditation. I am Micah and we have
a great panel of people today to share with you. First we will go through a few housekeeping
slides to get everyone prepped. The best thing first of all is to maximize your CCC confer
window. And if you happen to be on the telephone, again, we could turn it into presenter only
mode but I am hoping that everyone, if you happen to dial-in would just press star six
to mute your phone. That way everyone can hear clearly and speak clearly and not hear
any background noise.
If you have any questions, and I'm sure that you will, or have comments, please use the
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Adjusting audio. If you are listening in on the computer you will notice in the lower
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So, we're going to have a lot of information today see you can save files by clicking the
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There was a question will there be a recording available after the event. And the answer
to that is yes. We are recording this event. And the recording will be provided to you
and sent to your e-mail. A link to the archive, 48 hours after the presentation. As long as
you registered within the timeframe you'll receive this e-mail.
The next step is I'm going to go ahead and press star six to mute. Thank you.
So, I'm going to start the recording. (The recording is started). Actually, somebody
already start the recording.
So again, distance education on the front burner, new regulations, new challenges and
accreditation. And I will hand it over to Pat.
>>: Hi everyone. I'm a little nervous. Is quite a large group. And if you are on campus
right now I would probably be on stage doing a little dance for you but I cannot. So, in
your mind you can see me doing a little tap dance. I am really excited about this because
I think it is going to start something new for us with our accrediting agencies and give
us more connection to those folks who are trying to help us be the best we can be.
Today's seminar is brought to you in conjunction with at one. And the ACCJC which is a really
great partnership that I hope will continue. Most of you know me, I and the Dean of distance
learning and library technology. And I work a lot with the distance education coordinators
in the state of California. And there are a lot of you on that I can see which is really
I want to introduce the presenters very quickly. (on the board) (reading). I
want to
particularly thank Christopher all of her work in helping me. Between the two of us
we were able to get this cold together. And that is just the components of the slides
and all of that. And we hope it all goes smoothly. And our moderator particularly, Micah, I really
want to thank him for all his energy and work putting this all together.
So I will turn this over to Barbara. We have a lot going on in distance education and our
regulations and what the federal government is requiring. We are hoping to (inaudible)
our accreditation visit. So, with that I will turn it over to Barbara will talk.
>>: Thank you. I would like to just start by letting you know I am the president of
the ACCJC and I want to welcome all of our online guest from the institutions. I'm really
pleased to be a participant today in our first webinar. As Pat mentioned we are hoping it
goes well. We also extend our sincere thanks to Pat and to Micah for helping us. The webinar
is going to be stored at CCC confer or, At One. , The purposes of the webinar, you can
see three purposes there. The first one is to provide information and let you know what
accreditors are doing and help you achieve quality standards the Department of Education
has adopted new regulations that impact institutions that provide distance education and the impact
accreditors that review institution quality. The regulations are multiple. They occur in
multiple sections. And they are complex prints we have several experts here that understand
the new requirements. I think if you went looking to find you would have to look in
many places.
I am speaking on a telephone in a hotel room. That is why it may be hard to hear.
First, some introductory facts. First, there has been a national and federal increase in
interest in growth of education could have been significant increases in the number of
institutions offering distance education. There has been a huge increase in programs
that are offered solely by distance education. And then significant growth in student enrollments
in distance education. The 2008 federal regulations reduced the limits on federal aid for students
and rolled the distance education, and that is part of the explosion or increase the distance
education enrollments. And some of those enrollments have occurred at private for-profit institutions.
And as we will see as we go through this workshop, that particular area of growth has given rise
to other kinds of concerns that have come over into distance education.
There are associated issues or concerns about quality in distance education at the federal
level. And one of them is covered clearly in the federal regulations, and that is authentication
of the students who have enrolled in essence education. There are also many new pieces
in the regulatory language about accreditation and how creditors have to assure quality and
conduct a certain kinds of reviews during our comprehensive evaluation studies. And
just recently there is an emergent set of stories about emergent financial aid fraud
risk that are using distance education and in particular community colleges to perpetuate
fraud in distance education. So these are all things that have increased federal and
national interests.
Next slide. Certainly,
>>: You know what we're going to do is put it in presenter only mode. Because we are
still hearing the background noise. And then I will just ask you to press star six when
I get done so you can continue to speak.
>>: Certainly at the national level there is a recognition of the benefits of distance
education. And you can see some of the benefits, just some of them there on the screen (on
the board). Certainly the national policy has shifted to focus on completion. Distance
education is an important thing that enables community colleges to reach their goal of
producing an additional 5 million college graduates by 2020.
Next slide. But there are deep concerns about distance education that have arisen in the
last few years. And perhaps the story of-(brief interruption)
Perhaps the story of a small college that opened in 1918 in the Midwest and transformed
into thousand five to a distance education institution named Ashburton University. They
now have more than 80,000 students. This is a case that drove the concerns about distance
education to the national stage. Sen. Harkin health committee held hearings in the summer
of 2010 examining the quality of education at Ashford University. And I think many of you-
Sen. Harkins case and the discussion of the case repeatedly drove news about the case
to the headlines of the national newspapers. And there continue to be cases that keep the
same concerns of life and unfortunately, what has happened for those of us who believe distance
education is a really important and legitimate form of education, but concerns about fraud
have spilled over generally into distance education institutions great so we are undergoing
a new degree of scrutiny as this concern about fraud and abuse has extended.
Next slide. The ACCJC has concerns about distance education and I thought I would share a few
of them in the presentation today. First of all, there has been a tremendous growth in
enrollments in distance education. 129/134 of member institutions offer distance education.
And enrollments range from 12 up to 6749. A lot of the colleges are using distance education
to provide up to half of their in Romans. Distance education is an opportunity for growth.
The commission is concerned about quality. They do show that growth is occurring rapidly.
Sometimes it is hard for institutions to provide quality services because of the rapid growth.
The learning management systems are expensive and take time to install. We show that student
completion is generally lower in distance education then face-to-face programs. And
this is something that is replicated throughout the country. So we are sharing concerns for
quality. There is one other area of concern and not a substantive change. The Department
of Education requires institutions to have substantive change approvals from their accreditors
when certain percentage of the course can be taken to distance education. We know many
of the institutions we accredit can access 50% threshold without noticing it and they
failed to get substantive change approval. That failure has consequences for their financial
aid eligibility, and all participants should know that the department regularly calls the
commission to make sure about the accreditation of these programs.
Next slide. So here is what we hold gain from the webinar. Some detailed information about
the new federal regulations and/or institutional responsibilities. And some detailed information
about what the commission will be expecting of your institution when it undergoes evaluation
and review. We will share some interesting examples of issues raised large. And we'll
have a chance for questions and discussion and answers.
And I see-
>>: You made a statement about distance education classes and we're asking you to repeat that.
What institutions tell us to answer that question, institutions tell us when they provide data
for us that course completion rates are lower for distance education classes than they are
for face-to-face classes. And that is an issue that is replicated across the country.
I think with that we are ready to talk about stakeout position.
>>: If you could mute yourself let's see if that changes the static. It does not.
We will try to go through and hopefully we will figure out what the static is being caused
from. If everyone would mute that is presenting-
>>: Okay, if we could go to the next slide is authorization.
>>: Okay, hang on just a second. Can everyone hear me? Okay. I would like to introduce Sharyl.
It is really ugly now. Hope it is not. Anyway, I will let Sharyl go ahead.
>>: Can everyone hear me? Well, I thank you for the opportunity to be with you today.
I could say afternoon but it is not afternoon for everyone, I do not think. So I want to
first mention that Dr. Pam Shay was unable to join us at the last minute so I will carry
the load for everyone.
Notice on the slide that ham is the vice president for accreditation and institutional effectiveness
at Franklin University in Ohio. This is a nonprofit private institution. It is online
and also has some on-site academic offerings. They have students in 48-50 states have any
point in time. I am the vice president of regulatory affairs and compliance at the American
college of education in Indianapolis. This is a for profit online institution. We have
students in many states at any given time. If any of you were on other webinars that
I have participated in, I formally was at the hotel University for 11 years in state
regulatory affairs.
The purpose of our presentation today is that you want to share our combined years of experience
in managing state authorizations for the 2 different types of institutions. And without
Pam there will not be quite the back-and-forth that we generally have with this presentation.
But we want to share best practices of the management of state authorization processes.
And provide insights and experience on approaches to successfully navigate the state authorization
The federal rules about state authorization says that if an institution is offering post
secondary education through distance education or correspondence education to students in
a state in which it is not physically located, or which is otherwise subject to state jurisdiction
as determined by the state, the institution must meet any state requirement for it to
be legally offering post secondary distance or correspondence education in that state.
>>: This is Barbara. I'm just going to interject on 2 slides. While the accreditors first thought.
Requirement would be an issue to be addressed by the institutions in the Department of Education
alone, we learned differently. Because federal regulations require accreditors to look at
student complaint records and processes when we undertake a comprehensive review. And then
also the new regulations regarding state authorization required institutions to make available to
students and names and contact information for all governmental bodies that approve or
license the institution. And therefore, during accreditation the commission can look at and
institutions list of their state authorities in the contact information provided to the
students on how to file complaints with the appropriate state or licensing authority.
You will see on this slide the evidence that the commission will require a comprehensive
review it however, the federal deadline for this has been extended to July 1, 2014. So
we have not yet sent these out-teens out to check on this. I cannot tell you how well
colleges are doing at providing this information yet.
>>: One quick question by Frank. Our trust territories exempt since they are not a state,
for example Guam?
>>: No, they are not exempt, but they have authority from the government, so you will
need to have your government, and office were students can file complaints with the state.
>>: To give a little bit of background, and Barbara has already touched on this, what
has brought the issue of state authorization from being kind of unknown to be very much
better known, is that the federal government published the regulations which expose existing
requirements for state authorization. So the new regulations from the federal government
did not create anything new as far as state regulations were concerned. However, institutions
then, many were unaware that they are and have been regulated all along. He states then
became aware of many institutions that were operating in their jurisdiction that they
did not know about before. And as a result a lot of confusion and a degree of panic in
sued on the part of the institutions. I am just going to touch briefly on the recent
activity where the District Court vacated portions of the regulations and there was
an appeal. That vacating was only on process, and it has nothing to do with the fact that
the state regulations are still in place, have been in place, and the federal regulations
does not negate what state regulations have been all along. And that has been a major
source of confusion I think on a number of fronts.
When it comes to authorization, another misnomer can be that institutions think that it only
pertains to having distance educators in the states. And that is not the case. It does
apply to distance education but there are a number of triggers that make it necessary
for institutions to get authorized to operate in states. One can be students residing in
the state. Distance education students residing in the state. There are not a lot of states
that have that but there are a few. Other states may have the regulation that if you
have any faculty who reside in a state, even if they are teaching students online, but
if they reside in a state that can be a trigger for physical presence which requires state
authorization. Recruiting and advertising is very common, and of course there are different
definitions of what that means in any state. But that is a common trigger. So that if you
are recruiting or advertising any particular state that could require you to have authorization
to operate there. Sometimes, although it is not common, testing sites can be a trigger.
One that is becoming more and more, our internships, practical, or clinicals. So, even if you have
a student is taking courses at a distance, but if they are required to do an internship,
a supervised internship, wherever they live, that state they have that internship activity
as a trigger for needing authorization. Branch campuses are always a trigger. This does not
give you an all-inclusive list these are common triggers.
>>: I will interrupt for just a second. I need all the moderators to please mute themselves
except for the speaker. And if you are not meeting yourself that way, please turn your
computer speakers off.
>>: Okay. So, we're going to talk a little bit about-provide some guidance for how do
you navigate (lost audio) upon which everything should be founded. There are multiple sources
available now as far as having leading up to the regulations.-I am sorry.
>>: Please hold on for just a second. Okay. I think you are good to go.
>>: Okay. So, the first thing we want to do is start with the official regulations. There
are multiple sources that are available now and we will provide links to those regulations.
WCET., There is at least one law firm that has a service for a fee where you can get
quarterly updates on regulations and any changes in regulations. However, it is also important
to know that the regulations are not always clear. And they are subject to interpretation.
And they do not always make sense. One of the continual challenges in the regulatory
world is to get people to understand that no it doesn't make sense but this is what
it says. Or it doesn't make common sense, but this is what it says.
If, where, and how to seek out the resolution, it all depends on several factors pretty depends
on the kind of institution you are, it depends on the delivery formats, and it depends on
the types of activities conducted within the state's borders. What I earlier called triggers.
So, in the case of-in some states, and will give you this a little bit later, in some
states there is an actual formal exemption allowed if you represent an institution that
is state funded. Or religious institutions sometimes are exempted. But you will want
to look at knowing what kind of institution you are and then go and look at the regulations
and figure out where you stand in the regulations. Based on the regulations you will want to
start creating your own table with all the states and what the various triggers are.
And then whether or not you actually participate in one of those triggers.
It is important to know where your students are. Because that is going to be one factor
to consider. When you get today regulations I recommend strongly that you first start
with the definitions. Because every state has its own terminology. And then you will
want to adjust your institutions terminology to match what is in the state regulations.
For example, I have used some here in the blue bubbles. Physical presence in one state
it will mean one thing, in another state it will mean another. The same with to operate.
Some states actually define it, other states do not have a definition. Educational services
is a perfect example. In some states educational services will spell out very clearly that
could be things like advising or a recruiting office or so forth. But it might mean something
else in your institution. An agent, even though the basic definition of what is a higher education
institution, there will be different kinds-in some states there will be different definitions
for different kinds of institutions. And want to find where does your institution fit within
these definitions. And as I mentioned earlier, the next part to go to is if there are any
provisions for exemption. And does your institution fall within that provision.
Doing the process of state authorization takes a whole team of people, and so we have just
laid out here a guideline to use as to how to put this together. What I have found works
best, and I know Pam does this the same way, is to have one person whose overall manager
of the process. And they then would gather a team of people together who have expertise
in various areas across the institution to populate this various elements within the
application itself.
You will want someone who is very detailed oriented in a multitasker. With some strong
project management skills and administrative skills. You want somebody, this is the manager
person now, you want somebody with a strong understanding of the entire institution. Because
these applications will include anything from an audited financial statement to enrollment
information to a description of the library to telling the state on which page of your
enrollment agreement this particular requirement is found. The catalog, all kinds of things.
It is best if you have someone who is connected with people across the institution. And someone
who is able to condense large volumes of information into usable documents and sections that need
to go into the various applications. Every state has its own form of application. Some
states the applications are more preformed. They will just give you almost like an accreditation
report where you will provide paragraphs of responses. Other applications will be you
have specific amount of information that you could fit within a certain piece of their
table and so forth.
You need somebody with a strategic perspective. Somebody who can help facilitate decision-making
in gray areas. Because although you would like to think that regulations are black-and-white,
they might be on a piece of paper, but they aren't when it comes to operationalizing them.
And this manager person also would need to be one who can participate in risk analysis,
because there is that involved as well. What level of risk will your institution be willing
to assume as they look at all of the information before them regarding where they would need
or want to give ways to operate.
It is important to build internal relationships. Because, as I mentioned a few minutes ago,
these applications will be requiring information from all areas of the institution. And again
this is not an exhaustive list. I'm not going to read it to you but you can see for yourself,
these are just nine areas, but it can be rather significant project.
You also want to build external relationships. This is really key. You want to develop relationships
with the state regulators. They are not bad people. The vast majority of them want to
help. They understand that to have the more educated residents they can have the better
it is for their state. So, they are not the enemy. But 2 things you should know is that
one is they are-their job is to enforce regulations that they were not responsible for putting
into place. They are responsible for adhering to them and enforcing them, but they did not
necessarily create them. The second is especially since the state authorization matter has come
to the forefront in the last year and a half-two years, they are absolutely swamped with work
and many of them have had hours reduced, and they have had to reduce staff because of the
cuts in state budgets. So as you are building this relationship with the state regulators
first again you review the regulations, the requirements, and then you approach them with
questions. It is not wise to approach them and say please tell me how to do this. You
are better off to have read it for yourself and then you can ask specific questions, how
does this apply to our situation here. Some things will be clear and some things will
not, but the state regulators will appreciate the fact you have done some of the homework
yourself, so you are talking from a perspective of educate-having already known something
and they are not having to read the regulations to you.
And one more thing about understanding the regulators is their perspective is consumer
protection and enforcement of regulations.
>>: Can you describe the regulators again very quickly.
>>: Yes, the regulators I am talking about now but generally-again it is different by
state-but generally it is somebody in a higher education commission function. Although some
states the regulator actually is the state university system. I can give a couple of
examples. Here in Indiana it is-I just moved to Indiana so bear with me. It is the Indiana
commission on proprietary education. In Minnesota it is the Minnesota office of higher education.
In Wisconsin it is the educational approval board. But it is generally an entity like
>>: Thank you.
>>: Sure. Another way to build the external relationships is to attend the regulatory
meetings and conferences. They can be ones that our federal, state is also, their individual
state agencies conferences. Volunteer to serve on state or national task forces. Represent
your institution at meetings and conferences. And then network across agencies and institutions.
Pam and I, she and I have over time built a great friendship because we do the same
kind of work. With some very different kinds of institutions. But we have helped each other
and we can bounce ideas off of each other as well as keep each other informed if we
hear that something might be changing the state or whatever as an informal way of keeping
abreast of some of those things.
Part of your decision in whether or not you are going to seek authorization to operate
in a state is the cost-benefit analysis. Some of the factors in that analysis are how many
students you have in a state, what activities does your institution want or need to conduct
within that state, how much does it cost for the initial approvals, to get the renewals,
to pay for bonds, what is the cost of not serving existing students, what is the cost
of monitoring and maintaining the authorization. All of these data points are important and
they are strategic decisions that need to be made. I have heard several times over the
last couple of years-are you telling me that our institutions may not be able to serve
students in a state? and the answer to that is yes, maybe. But that is what your individual
institutional have to determine. Especially, let's take for instance, I will pick on Minnesota.
Minnesota is a state where if you have students in Minnesota and you are offering distance
education to them, that creates a physical presence in Minnesota so you would need to
be registered with the Minnesota office of higher education. So, if you know that, then
from there you would have to do your cost benefit analysis. How much would it cost in
time and money to get that approval in Minnesota, what does it cost to renew, and all of those
things. It may be worthwhile for you, and it may not. But that is just an example of
what I am talking about.
>>: We have a question. Is state authorization done by the district or by college?
>>: It is done by college.
>>: Thank you.
>>: Want to have authorization to operate in the state it does not stop there. There
is ongoing maintenance. Generally you have to get reauthorized. And in most states it
will be an annual thing. Once you have gotten authorization to operate what you have done
then is put yourself under the jurisdiction of that state, which means if you're going
to add any new programs they have to approve that. There sometimes can also be an additional
annual reporting of revenue or enrollments. Sometimes if a state has a surety bond in
the initial approval, they would require you to renew that bond for the renewal application.
Some states, if you are sending recruiters into the state, on the ground into the state,
they require that those individuals be licensed as agent. And various states have various
processes and costs attached to that as well.
Even for exemptions, in some states and institution can get an exemption, a formal exemption,
but in some states it costs some money. In some states you still may have to report enrollment.
And in some states you have to renew even the exception. That process though is usually
much much less onerous than some of the other when you have to go for full authorization.
So what you would want to do is develop a system for regular review of your processes,
your information. I suggest you keep a record of some collateral material for instance,
many states will say what are your library resources. Keep that information someplace
so that you can just copy and paste into the next application. We want to make sure that
that information is the most up-to-date.
So that is state authorization 101, the very basic level. I would be happy to field any
questions at this point if you have any.
>>: Micah, do you want to go ahead with that.
>>: Yes, there's a lot of different chatter going on, and some of them I cannot tell if
they're just chatter amongst themselves or directed at the panelist. If you do have a
question, if you wouldn't mind typing that question in the chat box that would be great.
>>: I see one here, the last comment on the chat is from Jim. And I just want to again
reiterate that there are very few states were having students in the state trigger physical
presence. There are a few. So that is not true in all 50 states. And there has been
a lot of confusion, even with the federal regulation, some seem to think that that meant
you had to have state authorization in every state where you have students. That is not
what it says. What it says is you have to have state authorization in any states that
said you need state authorization. In that state.
So, then that goes back to what those individual state regulation say. And there are very few
that are having distance students reside there is a trigger. Is there a URL listing the widest
a regulators for certain area?
>>:WCET has that. If you go there they have links to the regulations themselves even.
Not just the agencies but also the regulations. I want to caution you though that all of that
information is a point in time. State regulations are changing all the time. So it is a good
place to start. It is an excellent place to start. But you cannot depend only on that
because that was created at a point in time. You still would want to go to the state website
and look to make sure that you are looking at the most recent regulation. There is also
another caveat to that. Some states have regulations and some have policies around the regulation.
So just keep that in mind. Some states have been really good in revising their websites
so that right on the front page it will tell you about state authorization and things to
look for. More and more states have done that which has made it a lot easier. When I first
started doing this work it was like trying to find a needle in a haystack.
>>: Another question. Would some regulations address the breadth and depth of student and
faculty assistance. Most distance education programs have only small staffs.
>>: Not know, it either is or it isn't.
>>: What are the average fees for state authorization?
>>: There is no average pretty depends on the kind of institution you are, in which
state. Some states it does not cost anything. Some states it is just astronomical.. It also
depends on how big your institution is.
>>: There are couple of states you are not doing business in, is that right?
>>: Yes, Tennessee is one of them.
>>: This is a question about this CCC Chancellor's office managing centralized approvals-a huge
burden that will be repeated several times (could not hear all of that). That is more of a factual
statement. Sorry about that.
Is there a database of state requirements?
>>: No. If you go back to the WCET information, that will give you a place to start.
>>: And also at the ACCJC website-and I will be sending out the end of this PDF with quite
a few links on it. You also get that.
>>: I see a question here what if the distance education student moves to another state during
the class and does not inform your institution?
>>: Factor that is even the information you provide to the state regulator, it also is
a point in time. So it is whatever exists at that point in time. When you do the renewal
then you'll have to look again and see where your students are and report your enrollments
accordingly. The state is not going to chase you down if one student-they would have no
way to know if somebody moved from one state to another during a class term.
>>: There was another question early on about international students. And I think I answered
it, but we will have to make sure that I am correct. And that is about the country. And
generally we do not have anywhere to find out that information. I think if students
are coming to us from outside of the country, you know, if we want to we want to make sure
that we know what that country requires, but generally I don't see-this is not the same
thing as what we do international.
>>: That is right. We are talking strictly-there may be things international. Pam would be
able to tell you that better than me. I am not familiar with it. But the focus of this
was all about the states and territories. US territories.
>>: Another question. We serve nonresident students in our regular classrooms, is that
considered a trigger? Nonresident is defined as out-of-state.
>>: No, in that case we're talking about distance students doing their course work in their
home where they live.
>>: And Jack wants us to remember that the emphasis on student may be receiving federal
financial aid for taking distance education classes. That is from the commission perspective.
>>: This state authorization has nothing to do with (inaudible).
>>: Andrea at San Diego and I have been-we have checked our rosters to see who was coming
in from out-of-state. And what we have done is we have looked for students who are in
our online programs but are not residents. Of California. And not just-they are fully
online, they are in our fully online program and they are not here. And that is what we
are looking for. We are not looking for students who are taking online classes and are also
taking face-to-face classes here. Because they are located here. That is another distinction
that we need to make. I hope that makes sense.
>>: Yes.
>>: And we have done the same thing at College of the canyons. And we also cross referenced
student athletes who were on team rosters. And a lot of our athletes come from out-of-state
and have out-of-state residents is, but if they are playing on a team here we know that
they are physically present here and they might be taking an online class, but if they
are playing the sport here we know that they are here.
>>: I think we need to move on now there but I just like to say that we are going to be
saving the archiving, the chat window here, and so we will try to get back to you all
with answers to some of these questions if we didn't get to them could soak we do not
get your questions we will try to get back I answered them. And we will move on and we
are moving on now-
>>: Excuse me, can I just make one comment. I see there is a statement here from somebody
who says if one runs ADE program were students do not receive federal financial aid, this
is a non-issue? that actually is not the case. It has nothing to do with financial aid. It
is whatever state regulation say.
>>: But that is one of the things that the commission is concerned with. So, just so
you know. We are going to move on and we are going to talk about student authentication.
And we have with us James who is from College of the canyons. And he has been researching
this for us and has also done quite a bit of work with our distance education coordinator
spreads I would like to turn it over to him right now.
>>: Hi everybody. Thank you so much all I can say is wow, it seems like I have an easy
piece to cover. It only requires you to play nice with everyone on your campus. So that
is really good. And also I get to be followed by Jack from the commission who might give
us more concrete answers. So I appreciate having an easy bit here. I want to say thank
you to Micah and Pat for organizing this. And a big thank you to the ACCJC for the rich
Are going to go back one slide. And you have time to look at this cartoon from the New
Yorker back in 1993. I wonder if anybody remembers this from the old days but some of the early
doctors might remember this. Once upon a time one of the great promises of the Internet
was that you could be anonymous, right. Back in the early days as a teacher, on my teachers
families to say to ourselves gosh, the students can be completely anonymous online. Their
ideas can speak for themselves but that is a good thing. But things have evolved over
time and that is no longer the case. And we now have to address this topic of student
authentication or verification of identities as it has been called. And this has been around
for a couple of years. I want to provide a little bit of background and a couple of ways
in which institutions are dealing with this and addressing it. And then we will be fortunate
enough to hear from Jack, the vice president of the commission who will tell us in detail
what the commission is going to be looking for.
>>: Before you continue. A couple of people have joined back into the conference, please
press star six on your telephone.
>>: Did someone go from a headset to something else?
>>: Hello, is that better? No. I don't think it was me. Obviously someone has a computer
speaker on.
>>: Thank you.
>>: Whatever happened, please keep that. So, some of the background on this authentication,
student authentication, is there is-this originated in law in 2008 with the higher education opportunity
act. This keeps on giving for those of us who are involved in distance education. That
was the updated higher education act. That was a federal bill. And once federal legislation
is passed a process called negotiated rulemaking takes place in which the representatives of
the department charged with enforcing the law, in this case the Department of Education,
engaged with in the negotiations, if you will, with her percentages from the deal. I know
there were several people at the table and organizations were at the table. A set of
this is going to become a reality what does it really mean. So, what we have is a set
of requirements that has already been shaped by input from the field or by representatives
of the field. What we have from the lot is in this paragraph here (on the board) (reading).
So, I have added emphasis to all those various components because it is not a matter of is
that student was in my class today the student who he or she claims to be, but rather the
question is a programmatic one overtime. So again, going back to the idea of needing to
involve a variety of offices and processes at your institution. In answering that question.
So, over time there has been a lot of talk about how we should address this and there
are a lot of different ways institutions are addressing this. And I have collected a number
of those here. I will just run through those real fast. I think the most common one, certainly
within California community colleges, the most common approach to this is to require
all of your online classes to use the college learning management system. This is so that
the institution is then authenticating the student through a central unique username
and unique password over which the institution has control for which the institution ensures
is authentic.
Another way to approach this is to require that all distance education classes have at
least one proctored assessment. One high-stakes assessment that students have to come to campus
or come to some sort of proctoring center, show a valid ID, and take their exams there,
in a way in which somebody has some form of authority has validated or verify that the
student taking the assessment is indeed the student whose picture is on the drivers license
and so on.
Another way in which this has been addressed by institutions is to be a little bit more
up front about informing students of what students are doing when they login. The legal
obligation of students to be honest about their identity. So, I will let you read that
little paragraph under item 3 (pause). That is exemplifying what we here at College of
the canyons put on our blackboard page. Is one more reminder to the student saying we
really want to be sure that you are who you say you are.
>>: I'm going to interrupt you for a second. Because the additional piece to that is that
we are trying, what we're doing in training for our faculty is asking them within their
courses to have a conversation in their discussion forum about just this so that they understand
that they could be committing a crime by having someone else do the work for them, especially
if they are receiving financial aid. So we are having our faculty have that conversation
and talking to the students about why they need to be who they say they are. About having
integrity in their courses.
>>: Absolutely. I think that is essential in faculty training. That is absolutely essential
to have that conversation with your faculty to have professional development activities
with your faculty in which you are asking them how do you address academic integrity,
do you have a conversation with her students. It is not all about the gotcha approach. Certainly
that is one component. The cop approach, but also the educational approach is very important
and very widespread, and that is let's educate our students about ethics, about academic
integrity and make them an explicit part of what we do in the classroom. And certainly,
number of folks around the country and institutions around the country are utilizing other kinds
of technology, the retinal scan, the camera panning the room, and so on and so forth.
I think most of us are looking at the low threshold or low-cost software that we utilize.
There certainly are an increasing number of vendors out there who are happy to sell us
very expensive tools with which we can proctor our students taking the exams at home. We
can use all sorts of identity verification things. There are quite a few questions in
the chat window that I see. One had to do with the fact of if you require your students
to come to campus or come to a proctoring center or proctoring exam, what does that
do to the whole idea be fully online class. And I certainly have a lot of empathy for
you on that point. That is why I believe that we have some flexibility in the way in which
we approach this. These regulations. One way can certainly be to require everyone to use
your college LMS. The proctoring is not the required way to approach it. It is one of
the options I believe. And Jack will talk more about that specifically what the commission
is expecting. The proctoring is not the sole required way to approach this. It is just
one way in which you can approach it.
The second question would be, I guess would be related to the virtual proctoring where
you have to validate their ID with that number. The language that I have seen would suggest
yes, that virtual proctoring in which you might have a camera panning students test
environment, we might have a keystroke analysis going on while the student is taking the exam
or you might have a series of personal questions popping up every 10 questions or so. Those
kinds of evolving technical solutions I believe are accounted for in the regulations. And
what I think-I hate to say anything positive about this requirement, but I think one of
the few positive things about this requirement is that there is a menu-we are provided with
a menu of options in the commission, as I think we will see in a second one Jack gives
us his perspective, is the commission has given us a menu of options that permit institutions
to promote academic integrity according to their local cultures and their local budgets
as well.
So with that I am going to move on to Jack from the commission. VP of the commission
and we will find out what the real answer is.
>>: Thank you, James for the nice introduction. What I have to say will be just as engaging
in informing as what James just gave to us. The answers come from the colleges. The first
slide we do not have to go through it because it just repeats the federal regulation about
student identity. But this all came home to ACCJC a while back when it was brought to
the commission's attention about a student who applied to transfer credits into a college
for a bachelors of science in nursing program. And that student transcripts included one
semester in which the student demonstrated that he or she had taken 103 credits from
seven institutions in one semester. And that was somewhat startling revelation that yes,
this is really coming home to roost, that is just the general nature of delivery of
distance education seems to invite fraud and your cartoon about the dogs, you know up here
in Northern California there is even a country song about how we are all different when we
go online.
But additionally in the next slide, this demonstrates that not only is it that the institution has
to verify student identity, but institutions have to ensure that they have policies in
place to protect student identity, and if there are any charges or fees associated with
that verification process, those need to be communicated to the student up front. There
was a case of an institution at which the records of thousands of students, faculty,
staff, and others were hacked through a computer used to control the parking access on campus,
and so all the personal information that was connected to those students was hacked. So
the institution really needs to take care in ensuring, one, that they verify the identity,
and 2 that they take efforts to protect the identities of students once they have gathered
all of this verification documentation. So, the next slide talks about the different ways-and
you have covered them already, James, so the secure login and password is certainly a method
to ensure student identity. Probably at one point that was not to be the be-all and end-all,
but maybe not so much anymore. Proctored examinations have been discussed and I have something further
to say about that later on. There are other new technologies and practices that have been
developed that are very effective, such as the turn it plagiarism programs, folks
that are in the composition department on any campus probably are familiar with programs
that check for plagiarism. And some of those can be employed in the identity of students
And one effective one is the regular monitoring of the engagement between students and faculty
members. Just like in face-to-face, online instructors can tell something about the personality
of the student by the way he or she responds, either in written work or otherwise to postings
to class assignments, and instructors can get a feel for what their students are like.
In fact, that can be built into the course through a series of introductory activities
where the instructor gets a feel at the beginning for what this person is like at the other
end of the computer screen. And then monitor that. When the person's personality into this
menu suddenly changes, that is a good indication that there might be somebody else is sitting
at the desk taking the test were doing the papers.
In the next slide talks about the learning management systems that institutions use that
are able to track the kind of engagement that I just mentioned between students and faculty.
And to ensure that those are regular and substantial, and if they are regular and substantial then
I think that will allow faculty members to have a sense of the identity of their students.
Some systems have been developed that allow colleges to verify regular attendance. And
those can be used and then the ones that I mentioned that English faculty should know
about is the monitoring the syntax up front of the written works omitted by students.
Paragraph when institutions look to have proctored test, done at libraries or in communities
where students are taking classes or at other institutions or something, they need to exercise
some care in the selection of those sites because you want to make sure that those sites
can be counted on. Also, careful thought should be done into giving the written assignments
so that faculty member should not use the same assignment semester after semester, but
change the assignments a little bit. Similarly, with test questions, they should not be given
semester after semester in the same order. Or even the same exact question. So there
are other things that institutions in the old days to sort of disguise from your section
a composition class. So you have these little built-in triggers that enable you to sort
of keep tabs on the student tendency to want to share information.
So, I think there are a lot of things that institutions can do and later on we will talk
about what the commission looks for when it sends teams out determine the quality of programs
that institutions.
>>: So basically what you guys are looking for is to have a seven career set of standards
for this. So, to me do some of the suggestions with a couple of them as James has pointed
out is you have to pick one of those that you have pointed out, and then as long as
we have a clear process, that is really what you are going to be looking for?
>>: Yes.
>>: And Mrs. James again. I have also found that a helpful component or one that at least
are encouraging, is to have an institutional culture that promotes academic integrity in
which the faculty maybe are not being policed in terms of what kinds of things they are
offering were using, but part of the conversation about quality teaching is should I be using
the same examples over and over again. Should I be having a conversation about academic
integrity with my students, so that kind of institutional culture.
>>: Absolutely, James for the issue of academic integrity is institutional integrity overall
pretty just takes on a different mask or takes on a different persona when you talk about
distance education. There are a few extra steps that need to be taken to ensure that
institutional integrity is maintained in that venue.
>>: So let me ask you a question, Jack that you have talked about before. And that is
as this develops we often times have faculty members who say my publisher provided material
let me do something that I can't do in my school of blackboard, for example. And that
faculty member will say I will let my students log into blackboard that then they are immediately
going to click on a link and go to that publisher material. Can you talk about that?
>>: I think Chris it will answer this one.
>>: We are going to have-in the next section we're going to talk about attendance and tracking
students who are active in the distance education environment. But these are excellent questions
for a distance education coordinator to engage with faculty and staff while they are determining
what they will do for orienting faculty or for orienting students in the online environment.
There are lots of what gets, and it seems that regulators are always trying to keep
one step ahead and at most sometimes they are keeping even with some of the tricks that
folks will try as they are tempted in the online environment. I
>>: I think there are things that you folks also need to know and that is that the commission
is actively working on educating the people on their teams to how to work with you on
what it is you should have in place. And if that process is completed I know that James
and I are both involved in that with a lot of other people. As that becomes a little
more solid we will get that information out to you so that we can be a little more clear
about it. There is also issues about the publishers that we really need to address in another
venue. That is a huge topic, but probably not in this particular venue.
>>: And I think you said earlier that the important thing is for institutions to have
policies and practices in place to ensure the verification of student identity, but
also as you might guess from the accreditation standards, that those policies, practices,
are reviewed periodically for their effectiveness in maintaining integrity in the institutional
>>: We are doing pretty well but I would like to be done with this next part. We are doing
pretty well on time. We can maybe take a question if you have any more.
>>: Can you have
only certain individuals to the proctoring?
>>: That is good question. The standards do not say that, and the distance education task
force that we are calling together for a second meeting later this month, we will discuss
that topic. But again, that just goes into the basket of a variety of things that institutions
can use it if they have success, demonstrate success with that method, then that could
be another piece of fruit in the basket.
>>: And I think that that is something that many of us to do is we do allow our students
in fully online classes to work with a proctored that is somewhere where they live, and then
we vet that Proctor. And some of us have processes about that that we can share with you as well.
Hopefully we can get our e-mails out to you so that you have that information. Go ahead.
>>: From an accreditors perceptive, when a policy is required (inaudible)?
>>: I'm going to take a stab at that. This is Susan. I think it depends on what the college's
able to reinforce and uphold. I mean is recommended practice is something the college can follow
up on and evaluate to make sure it is working. Or is a policy?
>>: So that is and it is to integrate Joel is your policy what you need in order to get
people to do what you are asking them to do is the answer to the question. So, that is
an excellent question. Okay, so can we go on them and we will happily try to come back.
>>: Okay, last date of attendance. That is what I'm going to be speaking with you about.
And that is something that does relate to financial aid. There is my it depends comment.
And I thought you guys might enjoy this little cartoon. Actually, I thought that Cheryl and
Pam with intranet also. So, you can go on.
The last date of attendance is the date the institution is expected to use to calculate
BMI out of title IV refund. Now title IV is financial aid, federal financial aid, and
so the league. The last date of attendance, the less refund that is required by the feds
for the financial aid money. So, the student drops of course for example midway through,
they have to pay back that money. If we can't provide them with information about when the
students last date of attendance was, then we are liable for that refund.
And recently, without the issuance of regulations or formal guidance, the Department of Education
has taken the position that documenting the students last date of attendance is an academically
related activity and it requires more than just attendance in the students electronic
classroom. Now, the implications with that are that-I will continue. Under both the current
and proposed department of education roles, if an institution is not required and is not
voluntarily take attendance, the institution may either use the midpoint of the financial
aid payments. As the effective withdrawal date or it may document the students actual
last date of attendance as determined by his or her last known academically related activity.
And what that should trigger for you is if you have to pay back money, you want to be
as clear as can be and have it documented when the last date was that that student attended.
Because that is going to be less money. And I think that some of our commission folks
can tell a story about that a little bit later. I do not have any personal stories about it.
I think we did have to pay back some money once. It was about $20,000 that we had to
pay back. Some of you may have more horror stories about that.
This is the implications for us. Traditionally we calculate that last date of attendance-that
could be off of the data that we receive in our stacks from our course management system.
And that is a little spooky, because we have been using that, and honestly that is not
going to work anymore. And that is what this new regulation says. Is that we cannot just
use that anymore. We could use it before, but not now. And that is that they are looking
retroactively. And I do not know how far back they are going, but they could look retroactively
at that. And you know why, because of the student is just checking into their course
management system, it doesn't say that they are doing anything. So, the Department of
Education has taken the position that documenting the students last date of attendance is an
academically related activity and requires more than that. So, what does it require?
Academic engagement for online grommets. In that, academic engagement, some of the snow
is regular effective contact, some of us know that as substantive contact. It is contact
with the horse, and it is engaging in activities of the course. So, that is a little bit different
than just attending. So think about that for just a second. Any face-to-face class you
have a student coming into your class and that student coming in, even though it may
not be turning in any work or may not be engaging in the activities of the class, unless they
have their head down on the desk and asleep, there hopefully picking up something. And
they are putting that effort forward and you know they are there. Were just looking at
staff in an online class, you don't know that they are doing anything besides logging in
and then going to watch TV or go to a baseball game or whatever and come back. And you don't
know. So there is the difference.
So I think I mentioned this before, this is where they are talking about regular substantive
interaction and engagement. And I think that the word that we can use these engagement.
And they are saying to discussion board post, completed assignments, or electronic conversations
with faculty. We probably have some other definitions that would hold for that as well.
Outcomes. The Department of Education admits that there is no prior general guidance supporting
its position. But it is retroactively requiring these program practices. The ultimate bad
outcome is an audit that finds a program lacked sufficient engagement and should be classified
as correspondence study which could make them ineligible to participate in title IV programs.
So I think all of this is tied back to the money, it is tied back to the financial aid
piece. You may have to pay money back or become ineligible.
So what are some things that we can do? We can make it clear to online teaching faculty
that course management system statistics are not enough. And we can define what regular
effective contact is, define what engagement is, and do that as a policy or practice at
your college. We have a regular effective contact policy, and James, did you want to
talk about that for just a second, with what happened to you?
>>: Thanks, Pam. At College of the canyons we were one of the fortunate schools to be
a test case for the Department of Education back in 2010 I think it was. And with a week
and a half notice the Department of Education came and conducted a title IV financial aid
audit of our campus, specifically looking at distance education. The auditors were very
professional, very polite, very friendly, and very nice and very open about the fact
that they were responding to Sen. Harkin things in Congress, and in their words they said
it had sort of forced the department to go after the for-profits, the big bad actors
and the for-profits and they have to be covered by going after some of the public spirit and
we were one of the public's that they chose. We passed with flying colors, so everything
turned out fine, but they were very open also about the fact that they had not informed
the field that the regulations would not go into effect until July of the following year
and they appeared in September of the previous year. But again they were very nice and we
passed with flying colors and it took a lot of work.
>>: You also had a policy in place, and we need to talk about that a think that is a
really important piece as well. I think they put that in the resources for you as well.
Paragraph we talked about I said we have a policy for engagement. And that policy needs
to be enforced. You need to have a policy that the instructors need to save the work
of the student who dropped and document when the activity stopped. The institutional definition
of excessive absences is also something that you might want to have. And this is for your
regular (inaudible). I asked a lawyer at a conference recently what we can do about getting
a drop policy that would work for our online courses. And her suggestion was to define
excessive absences as an institution for on ground classes, and then translate that into
an online and how we would use that for online. So maybe the first place to start as far as
when-are you going to drop students and when are you going to do that and how are you going
to do that. And be sure that your institution has defined excessive absences. And that our
college we really-we have something that we all pretty much use, but I think we need to
be really clear that it should be the same for everyone.
And some samples, you may have some samples, if you have samples of you could put your
name up there in the chat window where we could contact you at your college about those
samples, we might be able to collect some of those. Ours is right now when a student
has not participated in discussion or other forms of communication and/or has not turned
in assignments for two consecutive weeks the instructor will attempt to contact the student
and notified them that they have five days to complete or will be dropped from the class.
And the instructor will also document the students work until the point of dropping
the students. This is real for us when we put that in there. And a little bit scary.
We had some real incidents in the last few weeks where we have had people really upset
about we have dropped them from their course, but the instructors, bless their hearts, had
done what we asked them to do in their syllabi and a note that said exactly discreet if you
do not engage, and here are the ways that you engage, if you do not do this, for two
weeks, I will drop you from the class. And because the instructors had that in their
syllabi it was really easy to take that back to the student and say look, it says it right
here. One of our students is that he just changed the syllabi. But we have a copy from
the beginning of the semester on file and we were able to pull that out and say no,
it has been that way. So, sorry, you are not doing the work and we have the documentation
to show that. And he said I had been checking in with the class, and we said yes, but that
is not enough. You have to engage in activities.
So I think that is the end of mine. If you have those samples if you could post your
name and college in there and we will contact you. And Jack, I think you're going to comment
a little bit on this topic as well.
>>: Yes, actually, as part of the section on evaluating-I guess that is next. Sorry.
Okay, I am back on.
>>: Did you have any comments on the last day of attendance?
>>: No, not specifically. But I think it is good when you make such a policy institution
wide and that you put it in the syllabi for all of the forces. Under that is a contract
between the student and the instructor.
>>: Absolutely.
>>: Okay. So, when it comes to evaluating distance education as part of a comprehensive
or other kinds of visit to an institution there are several things that the commission
will expect colleges to have a handle on. And one of them is does the institution know
where it distance education students are located. And then that will enable it to identify the
state which it needs to seek state authorization. So, the first thing is do you know where distance
education students come from.
Accreditation expect that institutions have policies that define regular and substantive
interaction or contact between the faculty and the instructor for distance education
courses. And we will look to see that those policies are in place and that they are being
Teams will look at what kinds of special training are provided for faculty who wish to move
into the online environment or when faculty are hired to teach an online course, what
special qualifications that exist for those kinds of faculty.
The next slide continues this thought. It says that the college should also have in
place processes by which it prepares students to be successful in distance education courses
and monitors their success throughout the semester. Some colleges I have heard have
an orientation for online students that must be completed before students can roll. And
it talks about readiness for online education, student responsibilities, and it lays all
of this up front and requires that all students that take online courses complete this orientation
The colleges should make sure they are gathering evidence about their distance education students.
The student use of support services, counseling, advising, also learning support, tutoring,
labs, library, etc. They should gather information that would verify that the students are undergoing-to
what degree they are undergoing identity validation. And then to have policies on regular and effective
contact between the faculty member and the student.
And the final slide on this section says that colleges must ensure that there are policies
that dictate satisfactory progress in a distance education course. And this would include the
last day of attendance-you should have policies on how institutions expect online instructors
to report this information. Paragraph also, that institution assures that it's online
learning and support services for distance education students are comparable to those
that are offering face-to-face students. The issue of comparability of quality programs
and services to students is an issue that the commission is concerned about. Just because
it is offered online doesn't mean that it is any less-of any less quality or that it
is supported by any less services to students. It does not have to be identical services,
but comparable services.
And then we always tell Dean in our trainings and institutions that are undergoing evaluation
trainings that they need to analyze data for their distance education students and compare
it to face-to-face students. So if you have a composition class for example and you have
10 sections that meet face-to-face and the equivalent of 2 sections that meat in an online
format, how are those online students, how is the delivery of that course doing in comparison
to the face-to-face students. And if that is identified as a gap in expectations, so
the face-to-face students are continually doing better, achieving or learning more,
then the distance education students, then what's in our processor program review and
analysis of student achievement and learning information, then what steps would be institution
take to increase the success and the learning of students that are involved in the online
And then are sufficient college resources available and are they being used and are
they being planned for sustainability for human resources, technology resources, and
financial resources, are they used in support of distance education programs and services.
Any comments?
>>: In the time of budget cuts to what extent can an institution say it no longer provides
certain support services to online students because of lack of budget?
>>: I suppose I would have the same reaction at the said for students were taking the courses
face-to-face in our satellite campus in the Valley, or out in the mountains or whatever,
they are no longer going to have access to our tenured faculty and they will all be second
string faculty, ones who could not get tenure and we are shipping all of the old laptop
computers and all of the old textbooks as we we come out of our library, we are shifting
them out to our off-campus site. That would not be accepted. And an institution would
not advertise come to our main campus and get a high-quality education with top-notch
faculty and great facilities and technology to enable you to be successful, but take our
online courses or our courses offered at our satellite centers in be at a lower quality.
>>: One other question. Will everything in the guide be evaluated, and the self-study
guide (inaudible)?
>>: The self-study manual is a manual for the two years of preparation in the writing
of the evaluation report. The guide, and it encourages and it is to be used in conjunction
with the guide to evaluating institutions and the guy to evaluating distance education
and correspondence education. So, those three manuals are taken together. And the 2 guides,
as you know, break the standards by standard in subsection of the standard, and then ask
questions that colleges should use to ensure that we meet the standards and teams are using
those same 2 manuals and the same list of questions to determine if an institution meet
the standards. And at the end of each of those standard sections is a list of possible evidence
that an institution can offer up to verify that it meets the standards. So, I do not
see those things merging together. I see them as 2 guides being used by both teams and colleges
undergoing training.
>>: If the majority of our students enrolled in distance education courses reside in our
area and take on campus classes as well do we need to provide comparable services at
a distance? I think the question there is is the majority of the students.
>>: The answer is no-yes, they do need to provide students for students at the distance.
They need to have access to the entire set of supports that the education offers.
>>: Pretty clear. We have to move on. We have about 20 min. left, so we have a bit to cover.
So, I'm going to turn this over to Barbara. She is back, and Krista, or the $42 million
>>: Thanks everybody for this program. We think the $42 million question is one you're
going to be interested in. And you may not have thought about it. And it is whether your
program is distance education or correspondence education. Most of us have a concept of correspondence
that is rooted in the old paper and Postal Service model from years ago. These days the
distinction isn't so much about the meetings and the distribution as it is the manner in
which the instruction is handled. And this particular case study, and it is a real one,
a recent one, will show how close that line can be, and it raises some real issues for
practice in distance education programs.
So, you know, the regulations define what a distance education and also what a correspondence
education is. If you look at the bottom of the slide, you will see the reference (on
the board) (reading). 34 CFR is the Code of Federal Regulations that pertain to education,
and if you can find that, when you go online, if you do a little search for ECFR, and if
you suggested it is often you're going to want to look this up and book mark it. If
you look at this definition you are looking at instruction delivered to students who are
separated from the instructor, there is a learn substantive interaction between the
student and the instructor, and you are looking at a variety of technologies in delivering
that education.
Going on now to the definition of correspondence education you will see some similarities.
You'll see that the material can be provided by mail but also by many of the electronic
transmissions, but you will see that there is limited interaction between students and
instructors. And that interaction is primarily initiated by the student. So that takes us
to this particular-this case. (on the board).
And here is when the financial aid audit hits the newsprint some of you may actually have
seen this report in the Chronicle of Higher Education. There were other items that were
a part of the audit. I want to mention that. But we are going to deal with the main issues
that are about characterization of the courses and either distance education or correspondence
education. And just, you see on the slide, there were undergraduate courses and graduate
teacher licensure courses that were marketed under the colleges words external degree program.
And the courses were offered on that learning management system, with specific faculty assigned
to teach the courses, they were scheduled for a full semester, there was the option
for an extension if the work was incomplete. I am just setting this up so you can see that
they were not such an unusual place for our future punchline. And here is something go
about two thirds of the college students were taking some or all of their courses on this
online program.
So, those unfamiliar with financial aid processes might believe that the US Department of Education
audits financial aid primarily by looking at the financial aid office and how they qualify
students for financial aid and are distributing funds. But here is an example where the main
issue was in instruction. Look at what the auditors reviewed. They looked at program
descriptions on the college website, they looked at materials in the catalog and in
brochures. The interviewed students and faculty and administrators. They picked syllabi, not
randomly, they had them spread across the disciplines, and they picked ones where in
these online courses there were large enrollment. And then they went out to the learning management
system and they looked at the content and they also look at the tracking records of
student and instructor activities.
Okay, looking at the elements considered. This is how the auditors looked at the siding
whether classes were distance education or correspondence education. Look at this, the
system had features were participating in discussion boards, chat rooms, and viewing
videos. But these were not required. Reading was based on submission of assignments and
tests, not on any online communication. Let's think about courses and the colleges. Perhaps
at your colleges. You know, we do feel that there may be faculty members who are not fully
using one of the features of the learning management system. Well, okay, here we have
instructors who graded assignments and return them online. They were available to answer
questions, the periodically send messages to the students but they did not deliver lectures
or initiate discussions with the students. And the students decided whether they participated
in tutoring or other instructional resources.
So, if you are looking here, one thing that is striking is that it isn't that there was
no faculty interaction with students. Faculty did respond to student questions and did follow
up with students that seemed not to be doing the required work. But the auditors found
that level of interaction to not be sufficient in meeting the definition of distance education.
They looked at the syllabi and they noticed that the syllabi described the reading and
assignments and offered suggested schedules but the syllabi did not describe mandatory
or regular and substantive interaction between students and instructors. And more or less
the student posts and discussion forums were student driven. The grades were not affected
of students did or did not use the features.
So, think again about courses that we have, are there online faculty who don't really
change their syllabi between on-site and online courses? There are syllabi in the online classes,
face-to-face, generally set out kind of general expectations. They are not particularly directive,
they are primarily looking at written work and at doing test. So that may be an issue
moving that same syllabus to the distance education environment.
What were the auditors conclusions? Concluded that the entire college was not eligible to
participate in federal financial aid because 50% or more of it students were enrolled in
a correspondence courses. Those courses did not meet the definition of distance education.
And they recommended that the Secretary of Education require the college to return a
full refund of over $42 million.
So what are the potential applications for the college. Here the auditors were looking
at the actual practice. The effect of practice really has to be at the course level. The
auditors will look at syllabi, student and faculty interviews, it is not going to be
just a document review. And here, that little bullet, the second one, should kind of raise
alarms for courses where the discipline faculty me used to having to work primarily, the grade
primarily based upon written work or on tests. And these will fit the definition of correspondence
education rather than distance education..
So some advice for
online aided, on-site courses. Classes which are on-site but which include independent
online student work for some portion the instructional hours, should ensure the online portion the
class has elements of instruction and teacher to student interactivity so as to avoid having
the entire course defined as correspondence education. What we are suggesting is that colleges be concerned with that distinction
between substantive interaction with the instructor and putting the paperwork part on their mind.
Really, the key is regular and substantive interaction between student and teacher. It
has to be required in the course, that interaction has to be initiated by the instructor. It
is central in deciding whether something actually is distance education. It is needed in every
course that is fully online. It is needed in the online part of class if classes are
otherwise face-to-face. And it has to be demonstrable. It has to be documented. College documents,
including the syllabi and the learning management system and tracking system need to be able
to show and say that interaction. It is vital to a colleges relationship with the US Department
of Education for student financial aid eligibility. And of course it is key to quality education
and student outcomes that are required by the accreditation standards. And we really,
this is something that the entire commitment of the faculty teaching online is needed for.
One final note is this the college, was accredited by the higher learning commission. And the
commission has recently gone in and completed a substantive change review for the college.
They had changed the program in question from correspondence to distance education based
on a plan the college to put together. That said they were going to be more distance education
in the next semester. Well, the auditors found this did not absolve the previous activity
of the college. And it says the a creditor did not re-examine the program as offered
in the past. So moreover, the accreditors determination was that the program was no
longer a correspondence course was not binding on the US Department of Education. And what
that means is the accreditors really had to take heed of the Department of Education regulations
and rigor in their institutions. And even so, notice that looking to correct the situation
through a substantive change did not absolve the responsibility for the past actions.
So we have really a triad of accountability between US Dept. of education, the state regulators,
and the accreditation agencies. But on top of that we have to remember our primary accountability
is to the students being served, and in understanding and implementing these regulations we all
need to keep in mind ways in which student needs can be more effectively managed and
met through the impetus of these external entities.
Just to show you, I did have some regulations on here that when we get the transcript of
the presentation you will see that these are accessible to you.
Do you have anything they would like to add this particular case study, Barbara?
>>: No, you did a great job. But there's a question on the board and I will ask you to
upload the URL which has more information about the case to the session here because
folks have been asking about it in the text questions.
>>: I will do that. Thank you.
>>: Did you see other questions that need to be answered or, Barbara, did you want to
>>: Sure. So we are just in these that couple of slides we have laid out some of the regulations
for you. And in a sense we have already discussed several of them, but we have also put the
citations, should you wish to go look at these yourselves. As Chris to mention the 602 series
are regulations that pertain to accreditors. So if you want to see what we are supposed
to ensure or examined you can go to the 602 section. In the first is a verification of
student identity. The second on this page is that the quality of distance education
has to be equal to the quality of face-to-face education, but it also has to meet the quality
standards, the accreditation standards. And the third is that institutions have to establish
and maintain records to document their fulfillment of the college and program eligibility under
title for. And this is where some of your requirements as institutions to carefully
label correspondence and distance education classes and make sure that those attributions
are accurate, this is emphasize.
And in the next slide a few more of the regulations. (on the board) (reading).
And in the last reference to distance education again (on the board) (reading).
So, can advance our slides.
>>: And I just pushed a document to all of that has a lot of resources on it. It does
not have everything that is in the chat window though we have been putting up. But you you
can go to file and save and you can see the chat conversation if you want to will be saved
as a text file and that will allow you to have all of the ones that are in the chat
window, if that is what you would like to do.
We have just a few minutes for questions. Micah, have you seen any questions we may
have missed?(inaudible)
>>: I think I would call a correspondence that I think something needs to be clarified
is there is a difference between replacing face-to-face time with distance, with work
at a distance, and that is what we are talking about. Is the difference between a face-to-face
class that has activities posted online the students meet the required amount of hours
in the classroom than what we are talking about here. And I think, Barbara, is that
>>: I would just tell you all that the Dept. of education is frustratingly caught between
focusing on learning outcomes and the recent credit hours regulations. It is subject to
so much scrutiny because really for distant education they are looking at substantive
and regular interaction.
>>: I just my luck that because his probably eight or nine years ago that I started talking
about this an essential component of your course as a faculty member. I keep telling
people that is the central component. And this really has come back to the really true
in all of our regulatory issues as well. That is really what should be the central component.
There is a lot of questions about publisher materials that I think should probably leave
to another time and take up after the task force has met and discussed the top of the
publisher material.
We are about out of time and I would like to thank all of you who have come in here.
We have gone from 221 down to 182. But here's the survey that we would like all of you to
take a look at here. And Micah if putting in the chat window, and we would really like
you to fill that out to let us know how we did. I love the fact that you all were here,
and Barbara and everyone thank you so much for all the work that you put in. And we hope
that Pam is okay. She had an accident today and is in the hospital. But she says she is
all right. That is why she is not with this. But we hope that she is doing well. And I
think with that if there are no other comments we can sign off.
>>: Just response to a question about the power points. Someone asked if some of these
bullets are available in other documents. And they are but they're kind of spread around.
So this PowerPoint really list them the best. And I would like to thank at one and patent
everyone who participated in providing this workshop for our members and I hope it has
been helpful to you all. Thank you.
>>: Thank you, Micah.
>>: Just let everyone know that registered, there will be an e-mail coming to you just
a follow-up, it will have a survey if you do not have the time to fill it out right
now. And there will be a downloadable presentation as well as the recorded archive.
>>: Thank you guys.