Department of Education State Authorization for Distance Ed Regulations-A First Look

This morning the U.S. Department of Education released its proposed new regulations (press release, proposed regulations) for the state authorization of distance education programs. Institutional personnel and the public are invited to submit comments by August 24.

This post will focus on the contents of the proposal. In this post, we will:

  • Summarize the major compliance requirements.
  • Identify regulations that are new or have changed from previous versions. As you may recall, I was part of the Department of Education’s Negotiated Rulemaking team in 2014 and have a long-standing perspective on these regulations.
  • Identify language that we currently think will need more definition.
  • Highlight possible implications for institutions and states.

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

Notice: Just because your institution is a member of SARA does not mean you can ignore all of this.


Implementation Timeline

Remember that these are proposed regulations that are out for comment. The final regulations may change.

If the Department wishes for these regulations to take effect on July 1 of next year (2017), it must release the final regulations by October 31 of this year. All signs point to the administration wishing to clear out the remaining regulations (such as this one) prior to leaving office. If they have trouble completing the final document, they could release it by the end of the year.

The regulation is silent on implementation dates, which could be different than the effective date. Even though the regulation would take effect next year, they could decide to have a grace period before enforcing the regulations. On the other hand, institutions have long known that they are expected to comply with state laws and enforcement could start as early as next year.


Institutional Compliance

You Must Demonstrate Compliance: To be eligible for Title IV funds. It is expected that: “an institution offering distance education or correspondence courses to be authorized by each State in which the institution enrolls students, if such authorization is required by the State…”

  • As part of your Title IV reviews, you need to be able to show that you have the proper authorizations in any state in which you are enrolling a student who receives Title IV funds.
  • The “if such authorization is required by the State” is a big change from the Negotiated Rulemaking discussions as this language no longer requires each state to create regulations if they do not currently have them.
  • Implication: Colleges will need to do a better job of identifying the location of students enrolled in distance education or studying face-to-face in other states who receive federal financial aid. This is true even if your institution is part of the State Authorization Reciprocity Agreement (SARA).



Reciprocity Defined: The term “State authorization reciprocity agreement” is defined and is confirmed as a recognized path to authorization in other states.

  • Support for reciprocity has been in every draft and continues in this recommended language.

Consumer Protection: The definition of “State authorization reciprocity agreement” includes a provision that the agreement “does not prohibit a participating State from enforcing its own consumer protection laws.”

  • This is a new provision and probably arises from misinformation that has recently been circulated about the current SARA agreement. SARA allows states to prosecute fraud and misrepresentation claims in their own state.
  • Implications: The term “consumer protection laws” needs to be defined. If left to the states to define, then they could declare any requirement as “consumer protection” whether it is or not.


“Public” Notifications and Disclosure Requirements

The following “general” disclosures are required of those offering distance or correspondence students in other states. You can post these notifications and disclosures on your website. The proposed regulations define that these disclosures are required only for programs offered “solely” at a distance, which will limit the impact of this requirement since many programs are offered both on-campus and at a distance.

Authorization.  You must disclose the authorization that you have in that state and how you received it (through direct action with the state or through a reciprocity agreement).

  • This is new.

Student Complaint Processes: “Require an institution to document the State process for resolving complaints from students enrolled in programs offered through distance education or correspondence courses.”

  • You would be required to notify students how to submit complaints to both: a) the appropriate state agency and b) if different (such as in the case of reciprocity agreements) how the student may submit complaint in the state in which the student is located.
  • Notifying students about complaint processes in other states has been in regulation since 2011. We wrote about it and clarified it back then.
  • The further requirement to “document’ the State process for resolving complaints in each state is a bit confusing. Previous guidance (which is not technically void) allowed for a central repository of complaint contact information.
  • WCET is working with SHEEO to improve their list of state complaint processes. We will work to get a clarification from the Department and, if enacted, to create a resource to meet this requirement.

Adverse Actions. Notify the students of any adverse actions taken by a State or accrediting agency against an institution’s distance or correspondence activities in the past five years and  the year the action was initiated.

  • This is new.
  • Implication: The terms used by states and accrediting agencies are so varied that more clarification will be needed on this point.

Refund Policies. The refund polices that the institution is required to comply with in that State.

  • This is new.

Licensure and Certification Requirements. Does the program meet the requirements in the student’s State to allow the student to be licensed or certified or to sit for a qualifying exam.

  • This applies to programs that lead to licensure or certification in a profession, such as nursing, teacher education, or psychology.
  • This is a variation on language presented to the Negotiated Rulemaking Committee. At that time, the Department wanted to expand this requirement to ALL licensure or certification programs whether they were distance programs or not. This language limits the requirement to distance and correspondence activities. Furthermore, is also seems to limit this requirement to programs offered “solely” at a distance (excluding practica or internships), which will limit the impact of this requirement since many programs are offered both on-campus and at a distance.
  • In negotiations, we were able to get the word “academic” added to the language, so that it was clear that only the “academic requirements” were included. There are requirements (such as the applicant not being a convicted felon) in some professions that are beyond the institution’s control. In a conversation with Department staff yesterday, they intended to cover only those requirements within the institution’s control.
  • To quote: “For any State as to which an institution has not made a determination with respect to the licensure or certification requirement, an institution would be required to disclose a statement to that effect.”
  • Implications: Institutions will need to do more work in notification about licensure programs. We will need to ask questions about cases where licensure/certification boards will not opine on whether a program meets the State requirements.


“Individualized” Disclosure Requirements

Photo of a dictionary with the term "disclaimer" highlighted.

No disclaimers. We need to know where our students are and if the programs meet state requirements.

The institution will need to directly notify students (not just on the website or in the catalog) in any of the following scenarios…

Whether the Program Licensure or Certification Requirements. You will need to directly notify the student regarding whether the program does or does not meet requirements in the student’s state.

  • “To each prospective student, any determination by the institution that the program does not meet licensure or certification prerequisites in the State of the student’s residence, prior to the student’s enrollment…”
  • This is a variation on language discussed in rulemaking.
  • Marketing and website people do not like negative language, but they will have to deal with it.
  • If you enroll a student from a state in which you do not meet the requirements, you will need “to obtain an acknowledgement from the student that the communication was received prior to the student’s enrollment in the program.”
  • Implication: Better knowledge of both the student’s location and the requirements in those states in which you wish to enroll students is needed.

Adverse Actions. If a new adverse action is taken, students need to be notified.

  • This is a variation on language discussed in rulemaking.

Cease to Meet Licensure or Certification Requirements. If your program formerly meet requirements and now does not, students should be notified.

  • This is a variation on language discussed in rulemaking.


Face-to-face Instruction in Other Countries

Obtain Approvals in Other Countries: “Require that an additional location or branch campus located in a foreign location be authorized by an appropriate government agency of the country where the additional location or branch campus is located.”

  • This issue is separate from distance education and is about branch campuses in other countries. In the negotiations, it was clarified that this did not mean joint enrollment agreements that an institution has with an institution in another country.
  • Additional notification requirements about complaint processes are included.
  • Distance education in other countries is not referenced.
  • Implication: If you have an independent branch campus in another country, more compliance requirements are recommended.


Watch for more from WCET and the WCET State Authorization Network on this issue.

Disclaimer: This analysis was done quickly this morning. I apologize for any errors of misinterpretations.Russ Poulin holding a baseball bat.


Russell Poulin
Director, Policy & Analysis
WCET – The WICHE Cooperative for Educational Technologies
303 – 541 – 0305    @russpoulin


If you like our work, join WCET!

*1:49pm Correction – Implementation timeline correct to July 1 of next year (2017) not this year. – CM

You Too Have Déjà vu with EdTech Conferences?

A list of conferences in a circular pattern showing the seasons of the year

Higher-Ed Edtech & Innovation Conferences graphic from our Friends at EdSurge HigherEd.

We have all attended a conference and had that déjà vu feeling, where you look at the program and the attendees and have the sensation that you’ve recently experienced this same thing. If you Google EdTech conferences you’ll get a this lengthy list from EdSurge Higher Ed and more lists.

The upside is that tech-enhanced teaching and learning is well beyond the peak of inflated expectations and is a standard mode of education delivery.

The marketplace is still ripe for innovation and sharing of best practices and each EdTech conference brings its own unique twist and synergy to the mix.  In the mix, what niche does the WCET Annual Meeting fill?

The WCET Annual Meeting, in its 28th year, continues to evolve.  The second meeting, held in Jackson, WY, demonstrated the promise of a T1 line, which was a buried cable capable of a transmitting a whopping 1.5 mbps.  This year, in Minneapolis, October 12-14, in our pockets we will carry 4G cell phones capable of communicating at 100 mbps. Like our phones, our programming is also keeping a rapid pace of change.

Engaging Sessions

At the Annual Meeting, Jaime Casap, chief education evangelist with Google, will inspire us to look at how we can continue to make education a powerful, effective, and engaging learning experience.  Throughout the event, we will look at how virtual reality can take us places we never imagined possible.  We will explore how technology can improve or impede access and the essential role of an effective digital inclusion strategy.  As the leader in the practice, policy, and advocacy of technology-enhanced teaching and learning, WCET’s program includes several sessions on timely higher education policy issues, including a discussion with David Soo, senior policy advisor with the U.S. Department of Education and Burck Smith, CEO, with StraighterLine discussing “The Growth of Alternative Providers: Competitors, Partners, or Both?”  And if you are looking for an opportunity to discuss quality with the experts, bring your questions to the “Ask an Accreditor Roundtable: The Future of Quality” session.

The WCET program is a mix of concurrent sessions, roundtable discussions, general session panels, and in-depth deep dive topic discussions.  The in-depth sessions provide context from expert panelists, lessons learned, and strategies attendees can bring back to their institutions as well as small group discussions. This year, the in-depth topics cover the key issues of open content and resources, stackable credentials, and adaptive learning.   Not to be missed, a closing panel discussion with several leaders from innovation hubs from institutions across the United States, including an MIT media lab student who has launched her own open source content platform, FOLD , in Innovation Hubs and Labs: Driving Change and Creativity.

 A Comfortable, Manageable Size

WCET’s niche, beyond an emphasis on policy and practice, is the size and scope.  The meeting is capped at 450 attendees and tends to sell out.  This is intentional.  Attendees find value in being able to quickly build their network because they see their colleagues frequently throughout the 2.5 day event.  They appreciate the small group discussions.  The smallness and friendliness of the group creates an inclusive and collegial atmosphere.  The program has broad appeal, most in tech-enhanced teaching and learning will find something of value on the program, but the program is not geared to be all things to people in edtech.  The focus is on providing content that is current, timely, and helps decision makers inform their choices.

A picture of a very large sculpture of a bent spoon with a cherry in the dish of the spoon. All of this is over a lake at the Minnesota Sculpture Garden.

Minneapolis Sculpture Garden

Corporate Participation is Integrated and Not Focused Completely on Sales

What you won’t find in the sea of familiarity that is the fall edtech scene, is a large exhibit hall.  Expos are a great way to meet vendors, pick up swag, and see emerging products and services. But at the WCET Annual Meeting, we think that vendors can bring a lot to the conversation and by engaging directly with attendees, both can shape products and services. Corporate participants have the luxury of looking 5-10 years into the horizon and can help inform our practices. WCET invites corporate attendees to participate like any other conference attendee.  The EdTech Meet-up on Thursday provides a fun and informal networking venue for attendees to connect with corporate attendees as well as institutions showcasing innovative technology applications. The space is a casual area for networking and lounging while engaging with innovative leaders on the corporate and institutional side.  If you are vendor and are interested in learning more, contact us.

Come Join Us at the Annual Meeting in the Twin Cities

In considering where to invest your professional development resources, there’s a lot to factor in to the decision, and plenty to choose from.  View the Annual Meeting program, see why WCET is unique, and join us in Minneapolis in October.

Megan Raymond headshot


Megan Raymond
Assistant Director, Programs and Sponsorship
WCET – WICHE Cooperative for Educational Technologies



Photo credit:
Cherry on spoon at Minnesota Sculpture Garden. Photo by Josh Haroldson used through Creative Commons License.

Reflections of a Connected Learning Coach

For the past six weeks I have been serving as the connected learning coach for Collaborative Curiosity: Designing Community Engaged Research, a fully online, graduate level, connected learning course sponsored by the Virginia Commonwealth University (VCU) Division of Community Engagement and taught by Valerie Holton and Tessa McKenzie.

Like connected learning, which has been used in the educational literature to indicate everything from online to social to experiential learning, I suspect connected learning coaching can mean many things to different people.  In this case, I am a resource introduced by the instructors into a learning community to provide personalized student support related to the digitally networked participatory practices associated with openly networked connected learning.

Four categories of course goals: 1) you will learn how to..., 2) through critical dialogue around..., 3) In a connected learning environment using..., and 4) Te prepare you for.

Course Goals and Activities

The Context

Collaborative Curiosity belongs to a portfolio of innovative online courses that emerged from VCU Academic Learning Transformation Lab under the creative guidance of Gardner Campbell and Jon Becker from 2014 to 2016. Currently in its second iteration, Collaborative Curiosity takes place entirely on the open web. All course materials freely accessible on the public course website to allow for community participation and engagement in the course. Weekly synchronous class discussions take place on Twitter, and assignments are completed via blogging on personal student websites (a variation of Domain of One’s Own). The individual student websites are networked through tagging and RSS feeds to the course website so that participants, observers, and instructors can visualize the big picture of how participants are making sense of the materials and activities related to the course.

Course Homepage with course description, link to the course video trailer, and twitter feed.

Screenshot of the Collaborative Curiosity Course Home Page

The Inspiration

Based on my prior research, the digital landscape of Collaborative Curiosity – the blogging, the tweeting, and the openly networked course space – provides ample opportunity for students to engage in connected learning.  As described by the Digital Media Learning (DML) Research Hub, connected learning is an experiential educational approach that encourages students to recognize, strategically reflect on, and forge new connections between people, contexts, ideas, and personal experiences for the purpose of deeper, more authentic learning. Digital environments are particularly powerful connected learning spaces, because they allow students to access more resources and authentic audiences, express themselves through near-professional grade media, and make more immediate connections via hyperlinks and personal learning networks.

Having spent several years studying openly networked connected courses at VCU, I am convinced these environments are (potentially) powerful spaces with endless possibilities for inclusive, authentic learning.  Very preliminary findings suggest that most students find Collaborative Curiosity more engaging and equally as challenging as other instructional approaches while recognizing that it deepens their digital fluency, awareness of open scholarship, and perceptions of the professional and scholarly possibilities for online spaces.  However, the digital participatory approaches used in courses like Collaborative Curiosity are so novel that many students (and instructors) need significant pedagogical and technical support to take full advantage of the experience.  

In today’s higher education environment, instructors seldom have the time or resources to provide such intensive personalized support in any sort of sustainable way.  Hence the idea of a connected learning coach: a person that is neither an instructor nor a student, but rather a class consultant willing to provide formative feedback and technical support around digitally networked participatory practice for both students and instructors when they need it.

On the bloggergate page, samples of content posted by students are shown and the full content can be linked.

The Course: Bloggregate: Student posts are aggregated via tags and RSS feeds so that they can be viewed together.

The Role of a Connected Learning Coach

Given the highly experimental nature of connected learning coaching, the course instructors and I agreed to allow the defining characteristics of my role to emerge as the course took place.  Six weeks into the experience, I see my purpose in this particular learning community as meeting the following needs:

  • Promoting the pedagogical value of making connections. Let’s face it – most graduate students already know to make connections between their work and traditional information sources such as scholarly research articles (it’s called “citation”).  These connections are important, but connected learners look for other types of connections in their school work as well.  They connect to the ideas of their peers, through their own work over time, and across contexts (e.g. work, hobbies, other courses) and modalities (e.g. images, music, kinetic movement). Documenting these connections through hyperlinks or embedded materials makes them explicit and immediately accessible.  It allows a student’s thought process to be shared with others and provides a historical record to support ongoing personal reflection. Because these sorts of connections and their documentation are not often discussed in traditional classrooms, they need to be modeled and explicitly and consistently valued.   As the connected learning coach, I discuss these ideas in blog posts, tweet great student examples, and analyze student hyperlinking patterns in their blog post comment sections.
  • Helping students navigate digitally networked participatory culture. Many students participating in Collaborative Curiosity had never tweeted or blogged prior to the course.  Therefore, they were not initially attuned to the cultural nuances of digitally networked communication. Students and I have informal Twitter discussions on the nuances of digital workflows, Twitter, and self-promotion.  I performed a social network analysis of course Twitter chats as a means of formative feedback and shared personalized results with students via email. Furthermore, I wrote a blog post on the purpose of course hashtags and continue to monitor the course’s Twitter chats to capture and retweet any student tweets that did not include the course hashtag. Interestingly, students have begun to police their peers’ use of the hashtag, and my role in Twitter chats has declined.  

    course tags are displayed in a map format with lines showing connections between the tags.

    Mapping the links to course tags.

  • Providing technical and moral support. Despite written instructions, instructional videos, and a streamlined process (developed in-house at VCU Academic Learning Transformation Laboratory), some students still have difficulty navigating the technical process of establishing and personalizing a blog site, linking their sites to the course website, and creating posts. For generalizable assistance, I write blog posts based on common student needs. When real-time, personalized help is required, I use a combination of screenshots, email, and direct messaging to provide step-by-step support in a media in which the student is already comfortable. I even arranged a face-to-face visit with one student who was having trouble.

Initial Thoughts

The course is still in progress. Therefore, I only have initial thoughts on outcomes and impact to share. I’ve enjoyed watching students expand their digital communication and connecting skills quickly. Anecdotal evidence suggests these particular students have appreciated having someone there to help them with the technical aspects of blogging and tweeting. Furthermore, an initial, informal analysis suggests they are making diverse and powerful connections across the learning community and their own work.  Six weeks into the experience I’m focused mainly on staying out of their way as they continue to learn. Some things I have learned and will carry with me into my future experience:

  • Assessment matters. The Collaborative Curiosity instructors have always been explicit in their dedication to promoting digital fluency, open digital scholarship, and connected learning through their course. They reference it in the course trailer, course competencies, and the assessment rubric.  However, student interest in my blog posts, feedback, and assistance increased after they received grades on their first blog posts, which included marks for their digital presence. I am not sure students would have invested time in enhancing their digital skills or engaging in connected learning without the formalized connection to assessment.
  • Moral support is important.  Over the years I’ve assisted many students – undergraduate, graduate, professional, and adult – in digital learning experiences similar to Collaborative Curiosity.  Instructors are often surprised when students find it difficult to set up their digital workspaces despite ample access to written or screencast instructions. I have found that some students have a level of anxiety related to “technology” that prevent them from following direction – no matter how adequate the instructions are. Nevertheless, many of them are able to do everything required in the presence of real-time support. Students who ask me for technical help often answer their own questions without real input from me and go on to do amazing things on their own as the course progresses; they just need someone to be present at the very beginning of the process to boost their confidence.
  • Coaching takes time – but not necessarily instructor time.  Targeted blog posts, twitter conversations, personalized social network analysis, and one-on-one instruction take time – definitely more time than most instructors have to offer.  However, my experience suggests that instructors don’t necessarily have to do the work alone. Connected learning coaching can be performed effectively by third parties – interested community members, teaching assistants, probably even (and possibly more effectively) trained peer coaches.
Photo of Laura Gogia pointing at a computer screen while seated next to someone whom she is coaching. This is actually a Wikipedia editing event and not the course coaching referenced in this blog post.

Laura Gogia Actively Coaching


Laura Gogia
Independent Educational Consultant


Connected Learning Coach Blog Posts (to date):

Greetings from the #CuriousCoLab Connected Learning Coach

Why a Course Hashtag

Why Embed Images and Videos

Why Personalizing Your Blog Matters

Why Hyperlink Your Own Work?

Downloading and Printing: Thoughts on Info Dissemination

Reimagining Higher Education and the National Technology Plan

On the last day of June, the U.S. Department of Education hosted an invitation-only session on “Reimagining Higher Education.” I was very pleased to represent WCET members. Here are some of the top takeaways and notice that they are planning to include higher education in the national technology plan this year.  I’m asking for you input on what should be in that plan at the end of this post.

I don’t agree with all of the ideas that were expressed. What is clear is that changes are happening and we need to continue to pay attention.

The Administration and the Department of Education are Charging Ahead

Picture of the stately main building at Georgetown University. It looks slightly like a castle with a tall, narrow clock tower in the middle.

“Reimagining Higher Education” was held at (and partially sponsored by) Georgetown University.

Even with the election looming and the days remaining in the current administration are dwindling, they are not in a winding-down mode. Ajita Menon, Special Assistant to the President for Higher Education, said that the President is seeing the coming months as a “sprint to the finish.”

Ted Mitchell, Under Secretary of Postsecondary Education, said that there is “unfinished business” and the focus will be on:

  • Improving teaching and learning.
  • New business models for higher education.
  • Reimagining credentials.
  • Affordability for students.
  • Collect use and share data about learning.

Mitchell said they also would like to highlight the work that they have done in expanding the focus on postsecondary students beyond traditional 18 year olds.

Students Need Alternative Paths

In a Google Hangouts session with four students across the country, we heard about how student academic and support needs differ greatly.

  • A student in rural Texas talked about his need to borrow the single family car 2-3 times a week to drive more than an hour-and-a-half to access the internet for his courses. Neither his home nor neighbors have internet access.
  • A mature business woman loved Capella’s Flexpath (CBE-based) program as it recognized her prior learning. She also found that participating in online courses with inexperienced traditional-aged students was not fulfilling.
  • A student who recently graduated from the Galvanize coding boot camp in Denver said that he earned 160 college credits, but they got him nowhere. He saw little need for general education. He recommended that education teach skills in inferring answers rather than memorizing facts.

Is “Grit” Required?

What struck the audience about all of the students who presented was their incredible focus in overcoming obstacles to reach their educational goals. Certainly, people with personal or family obstacles often must call on reserves of fortitude. But, are we asking too much for first generation students to navigate byzantine collegiate systems? And, let’s not forget students like the one in Texas whose entire family is sacrificing to allow him to overcome issues of geography.

Alternative Providers: We Don’t Need No Stinking Oversight

Jake Schwartz of General Assembly (which offers certificates in mostly technology-related fields) said that he is often asked why his company does not seek accreditation. To that question he responds: “The RESULT in the accreditation. The employer is the only accreditor that matters.” He went on to say that this is NOT true of non-career programs (such as liberal arts degrees) and that we are confusing the two types of programs. Schwartz feels that confusion is dangerous.

The Importance of Employers/Higher Education Engagement

Jason Tysko of the U.S. Chamber of Commerce said that stronger “signals” from employers are needed as to what they expect from education. Jonathan Finkelstein of Credly said that a lifelong relationship with employers is needed. The tension between workforce and general education continues.

Alternative Credentials and Competencies are on the Rise

Holly Zanville of Lumina Foundation said that the Connecting Credentials repository (that Lumina is funding) is a first step in understanding the new world of credentials. Using the data about credentials that will be collected, they hope someone creates a Travelocity-like to help students and employers navigate through the universe of available credentials. Jonathan Finkelstein of Credly said that that employers’ reliance on institutional brand is ending. They need more information about the skills and knowledge of graduates.

Russ Poulin with a side view of the White House

Representing WCET at the meeting.

Investor Thoughts on Innovations

Paul Freedman of Entangled Ventures (an investment incubator) said that two innovations that they are exploring (and are being implemented by only a few) are: 1) programs that charge no tuition and students work half-time, and 2) upper division peer students help to teach lower division students. You might want to look at the twelve themes that Entangled Ventures believes, one of which is: “Low cost, disruptive educational models are likely to start outside of the US.”

Only the Elite Can Innovate?

Invitees were an interesting mix of people who have been involved in educational innovations. As happens in such events, there definitely heavy emphasis placed on work accomplished by big-name traditional institutions and by alternative providers. Of the 110 invitees:

  • Only four had community college connections (three colleges and one association),
  • Thirteen had public university connections (seven research universities, one online-only university, four university systems, and one association),
  • Regardless of sector, only two college-related attendees came from states ranked lower than 19th in total population and one of those institutions is located within a few miles of the District of Columbia.

Jeff Selingo, author and former Chronicle of Higher Education editor and one of the panel moderators at the meeting, recently wrote “Transformations Affecting Postsecondary Education” for the National Commission on Financin21st Century Higher Education. It is good piece on why there will be a certain amount of disruption (read that as needing to operate differently and/or with different players), but the “online education” section also relies solely on innovation at “elite” colleges.  Sigh.

A Higher Education Technology Plan – What Do You Think?

Joe South, Director, Office of Educational Technology, U.S. Department of Education, referenced the National Education Technology Plan, which usually focuses on K-12. This year they would like to include a higher education addendum. The second half of the day was spent working on suggestions for what should be including in the plan. They worked on five focus areas: teaching learning, leadership, assessment, and infrastructure. I volunteered to help with ideas on policy issues.

I’ll let you know if there are chances for you to contribute. Meanwhile, what do you think should be in a Department of Education technology plan for higher education??Russ Poulin holding a baseball bat.


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


If you like our work, join WCET!

Attacking Exam Cheating and Instilling Academic Integrity in Students

I have always enjoyed the “Spy vs. Spy” section of Mad Magazine. If you are not familiar with it check out this animated version.  In the wordless comic strip two spies battle it out against each other. The spies are identical except for one is dressed in black and the other in white. The comic strip is entertaining because every time one spy is confident that he has foiled the plans of the other spy some new technique or technology will be introduced to reverse the outcome.

hand and phone show cheating on testTechnology Can Enable Learning (and Cheating Too)

Those of us in the industry of exam proctoring can identify with this. Just when we get good at preventing cheating with one strategy, the students come up with another strategy. Once it was sufficient to not allow students to have their cell phones with them during testing. But now there are various forms of wearable technology that can be used to cheat. Sometimes it seems that even our best efforts only serve to keep the honest students honest. When a student is intent on cheating, they often seem to find a new way.

Just as technology can be a great tool for learning, it can be an effective tool for cheating as well. Some of the ways that students have indicated that they cheat include texting answers to other students during an exam, snapping pictures of an exam using their phone, using their phone to search the Internet for answers during an exam, purchasing term papers online, and creating fake test scores or letters of recommendation for college admission.

Many Students Admit to Cheating

The Josephson Institute on Ethics surveyed 23,000 American high school and college students about their frequency and perception of cheating. More than half (51%) admitted to cheating on an exam one or more times in the past academic year. Students were asked if they agreed with this statement, “In the real world, successful people do what they have to do to win, even if others consider it cheating.”  Fifty-seven percent of students agreed.

When asked by the Josephson Institute why they cheat, the leading responses included – peer pressure, to help a friend, the gains outweigh the penalties, low chances of being caught, pressure from expectations, and not enough time to prepare. As we prepare learners to be competent professionals in their careers, one very important aspect is to instill in them a mindset of integrity. To foster this culture of integrity, schools are using services that authenticate learner identity and monitor student performance during examinations.

Survey on Test Proctoring Perceptions

To contribute to the body of knowledge about academic integrity SmarterServices administers the Annual Proctoring & Learner Authentication Survey. The purpose of the survey is to collect data about good practices and perceptions using learner authentication and testing integrity services. While the Josephson Institute survey and others have focused on the event of cheating, this survey focuses on efforts to monitor student behavior in an effort to discourage cheating.

Responses were received from 365 persons representing the following stakeholder groups: Faculty (21%), Learners (15%), School Administrators (20%), Proctors (12%) and Test Center Administrators (32%).

The following findings from the survey are relevant to current practice:

  • The four most common proctoring modalities reported by faculty and school administrators are an approved human proctor (HR Director, School Principal, Librarian, Notary, etc.), local test centers, instructor as proctor, and live-virtual proctoring.
  • Faculty are most satisfied when they proctor their own exams or use a corporate testing center, and faculty reported the lowest level of satisfaction with automated virtual proctoring.
  • Faculty perceived an instructor proctored exam as being the strongest psychological deterrent to cheating and virtual proctoring as the weakest.
  • The proctoring modality which students perceived to be the strongest form of psychological deterrent was an approved human proctor. Automated, virtual proctoring was perceived as the weakest form of psychological deterrent. It is not surprising that students reported that their preferred proctoring modality was automated virtual proctoring. Students also reported that the proctoring modality in which it would be the most difficult to cheat is instructor as proctor.
  • Students rated comfort and convenience as much stronger factors in their decision about a proctoring modality than cost.

Complete survey results are available on our website.

How Can We Foster Academic Integrity?The logo for Smarter Services, Mac Adkins' company.

So what can be done to foster a culture that promotes academic integrity? I have had several conversations recently with faculty and proctors about the matter. Here are some actionable suggestions from those conversations:

CURRENT TECHNOLOGY – Rest assured that students will take advantage of the latest technology in their efforts to cheat. Faculty and proctors must stay informed about emerging technologies and their impact on testing integrity.

HONOR CODE – Each educational institution which measures mastery through assessment should issue an honor code to their students so that the students understand the expectations relative to academic integrity. One of the most common excuses that students make when confronted with a testing integrity violation is that “no one told me that doing this was wrong.” Students must understand how they should act with honor and integrity as well as the rules of what is and is not allowed. A part of the honor code should be the ramifications and punishments for violations.

INTEGRITY TRAINING – Students have differing perceptions about which behaviors are acceptable. A training program should affirm and encourage those actions which are honorable and inform students about the actions that are not honorable and the ramifications both professionally and academically. Orientation courses or new student experiences are great places for such training. Some faculty members have students sign an integrity statement as an early assignment in their course.

FACULTY INVOLVEMENT – When a faculty member is actively engaged in a course then the student is more likely to feel that cheating is a violation of that relationship. When an online course is taught in a fully automated fashion then the human element is removed and the student may feel that that they are not letting any particular person down if they cheat.

MULTI-MODAL APPROACH – Just like the spies, when students take all of their exams in the same context, they will begin to notice weaknesses and attempt to exploit them. It is a good practice for a school to provide several modalities of proctoring and not allow students to do all of their testing with one modality. Examples of testing modalities include – instructor as proctor, testing in a testing center, testing with an approved proctoring professional (I.e. a human resources officer in a corporation), automated-virtual proctoring, and live-virtual proctoring. Tools such as facilitate the work flow management in a multi-modal environment.

If you have ideas, war stories or success stories about fostering a climate of academic integrity, I would like to hear from you.Mac Adkins

Dr. Mac Adkins
CEO and Founder


Photo Credit: ini budi setiawan

21st Century Credentials: Telling the Story of the Whole Student

conference room full of peopleEarlier this month WCET’ers gathered in Salt Lake City to have frank discussions and hear from leading experts in the somewhat nebulous construct of 21st Century Credentials. There is no way I can replicate the conversations held, the discussions, the debate in a blog post. But I can distill some of the themes and learning I walked away with and point you to the resources from the 2016 WCET Leadership Summit.

Higher Ed Facing a “Trust Bust”
In our first plenary of the day, Mary Alice McCarthy of the New America Foundation confessed if you’d asked 5 years ago, she never would have guessed today’s conversation would be focused on credentials – I beg to say not many, if any, of us did. Sure, efforts like the Degree Qualifications Profile were underway five years ago, and Mozilla had started the Open Badges movement, and Sebastian Thrun was calling for the end of higher education as we know it through MOOCs. All of these conversations danced with the idea of alternative credentials and defining what a degree really means. They brought us to the place we are today, talking about credentials, how they relate to curriculum and enrollment and employment.

Ryan Craig, managing partner of University Ventures, started with two salient points about why we in higher education are having this conversation exploring credentials.

  • We’re beyond the ‘take our word for it’ era – there is a loss of faith in the greater community about what higher education does.
  • Technology has changed the game – learning is ubiquitous and is pushing higher education toward unbundling the degree.

We are facing, as Craig termed it, a “trust bust” – both from the employer community and our learners. They no longer accept “trust us” with regard to our faculty’s ability to teach well or the skills contained within a degree. Jeff King, executive director, Center for Excellence in Transformative Learning, University of Central Oklahoma shared that the academic record of the future needs to show what students can do – transcripts are too opaque and are no longer being used by businesses. Hiring managers are using applicant tracking systems with sophisticated algorithms to filter resumes by keywords and then doing their own testing of prospective hires rather than trusting their credentials.

This all adds up to a loud call, a wake up call, if you will to the higher education community to drastically rethink how we demonstrate student learning and credential achievement. It was noted that grades are a proxy not necessarily indicative of what a student knows because they can be effected or skewed by poor assessments and failure of work ethic (i.e. an A paper might get a C because it was 3 days late). This circles back to being able to show what a student can do – to providing work samples, the authentic assessments that underlie credentials, not just grades.

Tell the Story of the Whole Student
Throughout the next day, the theme came up over and over again of what I’ve termed ‘telling the story of the whole student.’ Tactically we talked about extended transcripts and portfolios, competencies with rich, authentic assessments that produce work students can showcase when they go out onto the job market. We talked about being inclusive of the learning that occurs in college outside of the classroom through work experiences, campus leadership experiences, and extracurricular adventures. We even discussed how internships and other experiences not sanctioned through the institution but verified by an employer or other certifying entity might be included in the students learning record. Moving forward it will no longer be suitable to our students or their employers to simply provide that they got a A in English 101 – they’ll want to know why, how and what evidence there is of the learning and the skills developed. It will take radical shifts in all of our systems – the alphabet soup of linked (or sometimes not) software that we use to track students fiscally, academically, and out into their time as alumni. And it will take collaboration – both internally within institutions and externally with employers and solution providers to make it work.

Empower Students in Their Own Learning Journey
It’s one thing to showcase students work through the next generation of learning record, but the added layer of complexity is helping our students understand why they are learning what they are learning and then be able to be self-advocates on the job market, using their work samples to illustrate what they know and can do. Two e-portfolio companies we had at the Summit Portfolium and Foliotek, both grew out of a pain-point for their founders. For Chris Miller, CEO of Foliotek, it was watching his newly graduated daughter struggle to showcase the knowledge and skills she developed when she hit the job market – leading a caring dad to attack it, ‘there’s got to be a better way.’ Similarly, Adam Markowitz, Founder and CEO of Portfolium, was literally a rocket scientist, his lifelong dream, who left in order to launch a marketplace to help students showcase the skills and knowledge they gained at the university to potential employers.

slide what do we mean by credentialsPortfolios are one way to help students explicate what they know and can do to employers. Another way, discussed at the Summit and through the many other connected credentials discussions  with Lumina Foundation, Corporation for a Skilled Workforce, IMS Global, and the American Council on Education, is to clearly delineate the competencies associate with the work students do in college. It was suggested in many ways throughout the two days, that institutions who are not working with employers to define the competencies they need in graduates, will be left behind. And that graduates who do not have a clear understanding of their competencies and the work samples that support them will then suffer on the job market as employers turn to competency hiring rather than depending on the proxy of a college degree.

Again, this is not an easy task – there is no silver bullet. No one thing that will magically make competencies apparent and explicable by students. No one thing that will integrate all institutional systems to support next generation learning records. No one thing that will satisfy employers that your students have the knowledge, skills and work ethic they need to succeed. But it will take one thing – collaboration – within and external to the institution. Opening a multi-modal communication channel between and among internal and external stakeholders is the first step in making these changes.

WCET is The Place
Our Thursday morning moderator, Nick White, WCET Steering Committee chair and director of competency-based learning, Capella University told the story of the last time he was in Salt Lake City with his family and his then 3 and 5 year old daughters were into both make believe and chores. So, he took them to a park in Salt Lake City called “This is the Place Park” which holds significance for the Mormon church as the very place Salt Lake was chosen for their headquarters. They had the time of their year beating the dust out of rugs. Nick then, far more artfully than I am here, tied it back to being in a room full of like minds. That WCET is The Place. Many of us may have a hard time explaining to our friends, to people outside of our area of expertise, what the heck it is we do. But here, at WCET and specifically at this Summit, we are among colleagues, where we can think bigger and can meet new people who share our passions, vision, and mission.

I encourage you to watch the videos, check out the slides, the infographics, the amazing twitter backchannel, and other resources developed in support of the WCET Summit. I invite you to join the conversation at our 28th WCET Annual Meeting (registration is open, the full program will be live soon). Engage with your colleagues through the WCET member email list. Because WCET truly is the place where ideas take form and colleagues share pragmatic solutions.


CaliMorrison0615Cali Morrison
Communications Manager

Pending Federal State Authorization Regulations-What Might Be Included?

It’s coming back! The federal regulation for the state authorization of distance education appears to be returning. The Department of Education submitted a proposed regulation to the Office of Management and Budget for its review. The abstract on the OMB website reads:

“The Department is proposing to amend the regulations governing the legal authorization of institutions by States.  The Department is also proposing to issue regulations for the State authorization of distance education providers and correspondence education providers as a component of institutional eligibility for participation in Federal student financial aid under title IV of the Higher Education Act of 1965, as amended.” 

We won’t know what exactly is proposed until they release the regulation for public comment. My comments in this blog post are speculation based on my experience and conversations with others who also are guessing on the content.The words "state authorization surrounded by all the state names.

A Brief History

As you may recall, the last time this regulation was considered was during the 2014 Negotiated Rulemaking process. I (with Marshall Hill of SARA as an alternate) represented the distance education community on the Program Integrity Negotiated Rulemaking panel convened at that time. One of the six proposed regulations that we negotiated involved the state authorization of distance education. “Consensus” to pass the regulations required every member to agree on all six proposed regulations.

The state authorization for distance education proposed regulation was one of two that did not reach full consensus. Not only did it not reach consensus, but a large majority of the panel members were against what was proposed. My blog post at the time gives more details on what happened and why consensus was not reached.

As a result, the Department of Education is free to issue its own regulation. My colleagues and I were surprised that it took them two years since the end of the Negotiated Rulemaking process to take action. One assumption is that the current administration is trying to clear out all of the remaining unfinished regulations prior to the next President taking office.

What Provisions Might Be Included?

Since it appears that the Department has not talked to the institutional members of the Negotiated Rulemaking process since our last session, the following list are my guesses on what will be included in the proposed regulations. A recent analysis by Cooley, LLP agrees with my opinion that they will probably not stray far from what was in the final proposal from the Negotiated Rulemaking process. Even though there was agreement on some of the elements of the regulation, the Department is free to propose something completely different.

Demonstrate Compliance. This is the most important provision. The institution would need to show that it has the right (whether authorization, registration, or other approval action) to serve students in each state (whether at a distance or face-to-face) in which the institution wishes to serve those students. The institution would need to demonstrate compliance during the financial aid review (lovingly labeled an “audit” by some) that is held every few years. Additionally, the Department may request this information on demand. Institutions could be asked to refund federal aid for students in states for which your institution cannot demonstrate that you possess the proper approvals.

Disallow State Exemptions. States could no longer exempt an institution. This is a common practice by states, especially for public and non-profit institutions enrolling students completely at a distance in the state. Many states did not encounter many (if any) problems with these problems. States would be expected to conduct an “active review” of the institution. I sincerely hope that the Department can define an “active review” for us as they failed to do this adequately for the rules regarding the authorization of in-state institutions. This issue was the major sticking point causing more than half the members of the Negotiated Rulemaking team to vote against the Department’s last proposal. SARA makes it less meaningful, but this requirement will be seen as an “unfunded mandate” by many states.

Support Reciprocity. While they cannot endorse the State Authorization Reciprocity Agreement (SARA) specifically, I continue to expect the Department to continue its on-going support to recognize reciprocity agreements as a valid path to authorization.

Exempt Military. Members of the armed forces, their spouses, or their children would be exempted for the purposes of federal financial aid. This would be at odds with some state laws, but we should work with those states to follow suit. Long overdue.

Increase Notification Requirements for Licensure Programs. As SARA requires, institutions should be more forthcoming when notifying students whether their program meets the academic requirements for programs leading to licensure (e.g., nursing, education, social work). I realize this is hard for licensure programs in some states. Some of the requirements proposed during negotiated rulemaking were amazingly complex. Let’s hope that they settle on a reasonable requirement and be prepared to do much more work on this issue. SPECIAL NOTE: Don’t be surprised if this requirement is placed on ALL programs that lead to licensure, whether at a distance in another state or face-to-face in the institution’s home state. Expanding to the every activity will be controversial.

Introduce a Per State Minimum. There was confusing wording in the final proposal that set a threshold as to the number of students in a state before needing to demonstrate compliance. However, it also allowed the state to overrule this minimum, which meant that this minimum would almost never (if ever) take effect. While it sounds nice, the ultimate outcome is probably to add more confusion.

The Death Penalty. If an institution loses authorization in state then the institution is expected to stop disbursing federal financial aid and must notify its students. This makes sense if the removal is “for cause,” but the Department should leave itself leeway to address special cases when authorization is lost due to the state’s error.

We also had three members of the Negotiated Rulemaking Committee at the WCET Summit last week give their opinion of what might be coming:

Next Steps and Timeline

Assuming that the Department is trying to release this regulation while the current administration is in office, then they need to release the final recommendations by the end of October. The following timeline


Action Possible Dates
Department issues regulation for public comment. Maybe by July 1??
Department considers comments and issues the final regulation. October 31??
Regulation goes into effect. July 1, 2017??
The Department will probably set later dates for elements of the regulations to be enforced. For example, if they require states to change regulations, states need time to make those changes. Dates specified in the final regulation.

In Conclusion

Again, the above are just my guesses as to what might be in the regulation. We should know soon. Meanwhile, I wanted to repeat my position on authorization that was in my blog post on the Rulemaking process from two years ago:

“So that you know where I’m coming from, unlike many in the distance education community, I believe that the states still are responsible for consumer protection and that institutions should follow state laws. I don’t agree with all their laws and regulations and processes and whatnot, but I’d rather work to fix them or create alternatives, like reciprocity.

I also believe the Department should be able to use a college’s authorization status in a state as a determining factor for eligibility for federal financial aid. I do not believe that the Department should impose its will as to what the states should use as authorization criteria.”

Let me know if you have additional information or questions.Photo of Russ Poulin with a bat.


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

If you like our work, join WCET!

Behind the Curtain: Lessons from a Modern Digital Marketer

Higher education has undergone a dramatic shift over the last 10 years, and so too has the world of marketing. In 2014, the Harvard Business Review stated that it could not think of another discipline that had evolved so quickly, except for possibly information technology. Those of us in higher education marketing, then, are at the crossroads of these two rapidly transforming industries.

The dramatic shift in marketing can be attributed to both the availability and rapid adoption of technology and the volume of data now available to marketers. Since marketers need their messaging to be where their customer target is, the adoption of digital marketing has skyrocketed. In Mary Meeker’s recently released annual 2016 internet trends research, she stated that U.S. internet advertising spend grew more than 20%, from $50 billion in 2014 to $60 billion in 2015. McKinsey reported that digital advertising was the fastest growing marketing spend category, increasing approximately 16.1% annually from 2009 to 2014.

Clearly, digital marketing is a vital channel for the modern marketer, but for many, it remains a mystery. My goal is to help pull back the curtain on digital marketing and share some lessons I have learned while leading the online marketing teams at Learning House, which in 2015 generated more than 65k prospective online student leads.

Digital Marketing and student decision making funnel

Increasing Brand and Program Awareness

Within digital marketing there are many different types and formats available to advertisers depending on the objective of the marketing tactic. If the goal is awareness of your college or university and the specific university programs, below are the most often used online marketing products.

  • Display – Display is the billboard of the internet. The most common formats are either image or text ads (see examples below.) You can purchase display advertising for a specific website (such as Social Work Today or Scrubs) or on a display network (the largest being the Google Ad Network, a.k.a. the GDN, which allows your display ad to possibly be seen on more than two million different websites). Using a display network allows marketers to start with a wide net of potential eyeballs and then narrow down sites based on either keywords or topics. One tool that can be helpful in display advertising is com’s free tool, which allows you to see what display ads competitors are running.

teaching is your calling. pursue it. ad for Lesley College

Maryville's MSN ad

  • Social – Social media sites can be used to reach potential students both as a paid and an organic, or free, avenue. The majority of social ads are image ads with limited text. Social ads typically add an additional layer of demographic and psychographic targeting options not available with display ads, such as interests, employer, age, gender and more. On the organic, or free side, of social media, providing interesting, relevant, shareable and on-brand posts are another way to grow brand awareness. On the paid side, more social media sites are offering advertising products. While Facebook has been offering paid advertising for years, more sites, such as Pinterest and Instagram, are also adding the capability. In addition, social sites that already offered advertising are expanding the kinds of advertising products available. For example, Facebook recently began incorporating forms in their ads as well as multi-image ads called carousel ads (see example below).

FB ad for grand canyon university featuring graduate

  • Content Marketing – With content marketing, relevant original content is created and used to boost brand recognition and increase traffic to your website both from referrals to this content and from internet search engines. The content developed is based on strategic keywords related to the degree programs the university offers. This content is then promoted either through paid tactics utilizing vendors such as Outbrain or Taboola or through free outreach to bloggers and other relevant websites. Some examples of this type of marketing include Home Business Magazine publishing Rivier University’s article “Working Remotely Works” and the Huffington Post article linking back to Touro University Worldwide’s article “The Divorce Rate and the Need for Marriage and Family Services.”
  • Digital Radio and Video – These marketing tactics are akin to offline radio ads and television commercials but moved online and with better audience targeting capabilities. Digital radio ads can be placed on streaming sites such as Pandora and Spotify. The top digital video advertising platform is YouTube but many other social media sites are adding video advertising, such as Facebook and Instagram.

Generating Prospective Student Leads

If the goal of your marketing campaign is student lead generation, you will want more targeted advertising that will reach individuals further along in their college decision-making journey. This type of advertising includes:

  • Search
    • Paid – Paid search advertising features text ads that appear on a search engine results page (example below), and is conducted through an auction where advertisers bid on specific keyword searches. Search advertising is hugely popular, accounting for 50% of all digital ad spend in 2014. It is often separated in to two categories: non-brand or brand searches.
      • Brand searches involve search queries that include a college or university’s name (i.e. “University of Kentucky degrees”, “Concordia University nursing”). Brand searches are typically cheaper to buy as universities other than your own would not be trying to advertise to these individuals and thus, there is low competition for these search terms. The audience reached is usually further down the sales funnel as well since they are already searching for your university specifically. The market for this type of search may be reaching saturation, however; according to Google, the volume of brand searches in education have continually declined quarter over quarter for the last several quarters. Their most recent Q1 2016 Education Search Analysis shows a 5% decline in brand education searches in Q1 YOY.Screen Shot 2016-06-05 2LH post
      • Non-brand search is when the search queries being bid on are those other than ones involving the school’s name (i.e. “nursing degrees in KY” or “online counseling degrees”). Competition can be fierce for non-brand search queries as these individuals are looking to go to college but have not yet selected an institution. According to Sparkroom, the average cost per click (CPC) for higher education branded terms is $3.25, compared to $20.83 for non-branded terms.
  • Non-Paid – Paid search is not the only option for marketers. Organic, or non-paid search marketing, can be extremely effective and provide a significant ROI. This type of marketing involves continually optimizing websites to appear as high as possible on the search engine results page for those keywords that are most relevant to the programs they offer. This is also known as SEO or search engine optimization.
  • Social – Lookalike – A few years ago, Facebook expanded its advertising offering to include the ability to target individuals who had similar characteristics to another audience, whether it be your most recent graduates or individuals who had visited your website. This type of advertising allows marketers to strategically expand your advertising reach to prospective students that “look like” those who have already successfully converted (i.e., current students).
  • In-Market Display – Google offers the ability to advertise to individuals who are actively searching and visiting websites that indicate they are currently looking for post-secondary education. These users should also be further along in their decision to go to college.
  • Retargeting – Retargeting is an advertising technique to try to convert those who have demonstrated interest but have not yet taken the step of becoming a lead. By adding a tag or pixel to your website or specific website pages, you are able to present advertisements to visitors as they go to other sites after yours. Some publishers also are able to retarget to a list that you upload to their site. There are many types of advertising available to target this audience. They can be shown display ads or even on future searches the individual submits on Google. Not only does this keep your brand top of mind for this audience, but you also can tailor the retargeted ads based on the user’s behavior. For instance, if the individual visited the financial aid page of your website, then the ad displayed would talk about the financial aid options your university offers.
  • Website Optimization – Each year in the Learning House and Aslanian Market Research Online College Students survey, online students tell us their primary avenue for gathering detailed information about a school is by going directly to the university website. In the past couple of years, the data has also shown that unlike traditional college students, online college students only request information or contact two or three schools, so it is critical to provide a good experience to those visiting your site. There are many tools available to help improve website performance. For data about evaluating page design and page content, we use Optimizely and Crazy Egg. Google Analytics is a free tool to analyze your website traffic and behavior. Another more qualitative resource I like for website optimization is Bob Johnson’s Link of the Week. Each week Bob provides examples to some of the best college websites for specific objectives or goals.

The Future of Digital Marketing

Digital marketing is ever evolving as the search engines change their search algorithms, the publishers expand their digital advertising products and consumers change their behavior online. One increasingly important area is mobile advertising. As consumers continue to increase their mobile utilization, it is critical that your website and your digital ad creative is friendly to those visiting from a mobile device, both in look and also content. Messaging platform usage (i.e. Slack, Facebook Messenger) are also expanding and will likely play a role in future digital marketing efforts. And of course, as consumers become savvier, it is up to marketers to work harder. Adblocking tools, for example, are expanding and hampering the efforts of digital marketers. Methods to combat that will be increasingly important.


I leave you with a few of my favorite resources to learn more about each of the above types of digital marketing.


wendy parrish linkedinWendy Parrish is the Vice President of Marketing for The Learning House, Inc. She has been in higher education marketing since 2007. Prior to that, she spent several years in both the real estate and consulting industries, including positions with Andersen Consulting (now Accenture) and McKinsey & Co. She has a B.E. in Mechanical Engineering from Vanderbilt University and an M.B.A. in Marketing and Finance from the Wharton School at the University of Pennsylvania. You can connect with her on LinkedIn at or follow her on twitter @wendillpb.

The Case for CACE: The Consortium for the Assessment of College Equivalency

Sometimes in higher education common sense and doing the right thing for students supersede competition, policies, and politics (SARA may quickly come to mind). An example, the newly-minted Consortium for the Assessment of College Equivalency (CACE), formed officially in 2015, demonstrates how those sentiments provided the impetus for six adult-focused colleges and universities to pool together their time, talent and resources. These colleges joined together to create a collaborative effort to facilitate the awarding of academic credit for workplace training and industry credentials among and between their institutions.

It started with an idea and two visionary administrators, one from Thomas Edison State University and the other, SUNY Empire State College, both well-established pioneers in the prior learning assessment (PLA) field. They invited colleagues from four sister institutions – Granite State College, Charter Oak State College, the Community College of Vermont, and Excelsior College – to join in their effort. Each an innovator in the recognition of college-level learning from non-collegiate settings, the six founding members of CACE developed – over the course of two years –  an agreement to increase the availability of credit to their students and establish standards for the review and recommendation of credit for workplace training and industry credentials.

woman working at computer with code on screen

© European Union 2013 – European Parliament

Differing from an individual student portfolio assessment for prior learning, the work of the Consortium focuses on the academic credit evaluation or review of structured training programs offered by public or private providers (corporation, municipalities, etc.) and of established industry credentialing or licensure programs (IT, Radiologic Technologist, etc.). Such evaluations result in credit awards accessible to any student/employee who successful completes the course, exam, or program.

Simply put, CACE allows each institution to share with its competitors what is often regarded as proprietary information–academic credit awards and official reports- as a means to better serve students. Members of CACE refer to this ability to offer credit for employer training and industry certification exams through an internal evaluation process as the “secret sauce.” It’s one of the best ways CACE institutions can serve working adult students (and employers), and this benefit may likely have helped to land some CACE members on the recent Forbes Ten Great Colleges for Adults Returning to School list.

When the founding members first assembled and gingerly shared these “secret” policies and procedures with one another, a not-so-surprising thing happened: they found they were all approaching the academic evaluation of external learning in much the same way. Still, that fact alone did not make collaboration an easy process; lively debates about semantics often stole entire afternoons. Ultimately, six institutions came to agreement on a common set of standards and a process by which ostensibly to share student recruitment and enrollment access from hard-won corporate partnerships…culminating in the procurement of signatures from six different provosts and presidents.

Why Collaborate?

Yet, the need to work together with like-missioned colleagues was apparent. With a fast-growing interest in the now forty-plus year old practice of recognizing learning that takes place outside of the classroom, both employers and students have become educated and savvy about partnering with and enrolling in institutions offering academic credit for their workplace training and other forms of prior learning.  But to award credit for credentials that have not already been evaluated by the American Council on Education (ACE) or the National College Credit Recommendation Service (NCCRS, formerly PONSI) can be a resource-laden process for institutions; hence, the idea of sharing academic evaluation reports was born.

That is not to suggest that resources were the primary driver behind the decision to collaborate. Enormous benefits – for student, employer, and institution alike – are inherent in the work of the Consortium:

  • Eliminates Transcript Barriers and Facilitates Transfer: CACE reduces the need for a student to enroll in and obtain a transcript from one institution in order to transfer workplace training credit to another participating institution. The six institutions have agreed to accept each other’s credit assignment directly – although each institution reserves the right to either deny and/or process the acceptance of those credits according to their own internal processes. At Excelsior College, for example, any credit recommendations for workplace training and industry certification that come from CACE must pass through the same faculty voting process as those resulting from an internal review.  Once accepted, the courses and programs are loaded into the student information system so students can benefit from the credit awards by supplying the required verification from the partnering employer, rather than an official transcript from the originating institution.
  • Increases Employee Motivation and Access. Employers wishing to extend the low-cost, high-value benefit of academic credit for their training programs will be able to offer their employees access to potentially all of the member institutions of CACE, not only the one institution conducting the original evaluation. This practice results in motivation for their employees to further their education, saving them significant tuition and time to completion by avoiding costly duplication of learning, and allows them to select the institution that provides the best fit for their interests and needs. In the near future, CACE members also plan to conduct joint evaluations with representation from two or more institutions’ faculty to facilitate important employer partnerships.
  • Offers Guidance to Other Institutions: Institutions new to the credit for prior learning arena can access – via creative commons licensing – the set of standards developed by CACE as they look to develop their own policies and procedures for conducting academic evaluations of external learning experiences for credit at their own institutions. Just as institutions look to the time-tested PLA standards issued by the Council for Adult and Experiential Learning (CAEL) when developing a portfolio assessment process, these open standards will save them time. As CACE expands, it is likely that institutions without the infrastructure or desire to conduct their own evaluations will be able to join the consortium and gain access to the members’ evaluation reports and credit findings.
  • Lends Credibility to External Learning through a Standard Approach. The consortium lends credibility and further validity to the sound practice of extending academic credit for alternative, structured learning experiences. Building on the foundation set by CAEL, ACE, and NCCRS, the Consortium helps to dispel the belief that institutions are simply giving away credit for life and work experience. A standardized approach helps to reduce variations in the amount of credit awarded for similar training programs and lends transparency to the process of determining credit for alternative learning. In addition, the documentation CACE’s work produces can also inform an institution’s traditional credit offerings in light of new requirements from accrediting agencies calling for evidence supporting the application of credit hour policies (as an example, see MSCHE (2016), pp.11-14).
  • Improves Internal Policies and Practices. Last, membership in a consortium such as CACE has provided the opportunity for member institutions to review their own policies and procedures in comparison to the established standards, assess where they fall short, and introduce best practice. For example, two institutions recognized the need to implement a more formal appeals process for providers to challenge the credit findings and resubmit new or updated information when appropriate. The result of Consortium membership has been improved processes at each member institution.

What’s Next?

The Consortium members recognize the significance of what has been accomplished and share a vision of serving as a regional, national, or even global model for other institutions with the potential to reach major employers and, ultimately, to better serve adult students. Within the next six months to one year, CACE has crafted a hefty to-do list for itself: create by-laws, agree on best practices, develop criteria for new membership, continue the conference circuit, seek grant funding, establish a web presence, and create a way to easily share information, among others.

The group currently exists on the beneficence of each institution and relies on voluntary participation from the respective staff or faculty overseeing the academic evaluation process. Each institution sets its own fees for evaluations and covers its own administrative costs. Consortium costs have been limited to travel expenses and donated meeting space (and sometimes lunch!) at a given member institution. Moving forward, there is a pressing need for a designated staff member to coordinate efforts of the Consortium, create and maintain a website and database for sharing evaluation reports, vet new members, and ensure longevity of this worthy effort.

For more information:

To receive a copy of the CACE Standards for the Assessment of Non-Collegiate Instruction or to inquire about future membership opportunities, please send an email to In addition, the CACE concept and resulting standards will be accessible soon on the Presidents’ Forum website.

Founding individuals and current staff involved in CACE include:

Linda Wilder, Charter Oak College; Elizabeth Gauffreau and Leslie Paul, Granite State College; Nan Travers and Patricia Pillsworth, SUNY Empire State College, Marc Singer and Jeanine Nagrod, Thomas Edison State University; Gabrielle Dietzel and Melissa DeBlois, Vermont State Colleges; Tina Goodyear and Tanya Scime, Excelsior College.

More information about CACE founding member institutions:


headshot Tina GoodyearTina Goodyear
Chief Operating Officer
The Presidents’ Forum at Excelsior College
Former Executive Director, Center for Assessment of Post-traditional Instruction, Training and Learning, Excelsior College

State Authorization Reciprocity Agreement – Just the Facts (and a Few Opinions)

“You can please some of the people all of the time, you can please all of the people some of the time, but you can’t please all of the people all of the time”.” – John Lydgate

Abraham Lincoln referred to this quote after a difficult experience with another candidate. We are human. We don’t always agree with everything we are told or see.  However, we do need to get the facts straight before we are vocal in our disagreement.

Recently, there has been some limited, but vocal opposition to the State Authorization Reciprocity Agreement (SARA).  The opposition has raised concerns specifically about abuse by for-profit institutions with a direct link to online education. One must be aware that abuse is not limited to the for-profit institutions and that many such problems occur at on-ground campuses not affected by SARA.

We condemn the bad actions of all institutions that employ predatory practices, misrepresent accreditation or authorization status, misrepresent job prospects and salary outcomes, and use high pressure sales tactics, whether for-profit or not.

Constructive discussion may be a cornerstone of American process, but allegations have been raised against SARA that requires fact checking.  To that end, we would like to share issues critical of SARA and provide some objectivity and facts about each issue.  Additionally, there are two documents that one should carefully review before making a determination of the feasibility or reliability of SARA.  These documents are: the Unified SARA Agreement and the State Authorization Reciprocity Agreement Policies and Standards. Both will be included in the new SARA Manual due out in June, 2016.

Myth #1:  For-profit institutions offer almost all distance education. For-profit and online education is conflated.

Facts:  According to the U.S. Department of Education’s IPEDS Fall Enrollment data for Fall 2014:

  • For-profit institutions enrolled only 30% of students who took all of their classes at a distance.
  • For-profit institutions enrolled only 17% of students who enrolled in at least one distance education course.

The closure of Corinthian Colleges last year was one of the most publicized and largest shutterings of a for-profit college in recent years. Operating under several names, Corinthian Colleges was a “career college” with the bulk of its students learning in a face-to-face setting.

For SARA, only about six percent of institutions participating in it are for-profit.  Most of them are public.

Opinion:  In a letter to the New York State Education Commissioner, there is repeated reference to “predatory online companies,” which is an apparent attempt to demonize all distance education providers. While there have been predatory online institutions, this reference is being applied very broadly.

There is often the suggestion that online education is synonymous with fraud. As shown with the Corinthian College case, misrepresentation and fraud can happen anywhere.

While trying to attack the for-profit colleges by assailing SARA, there is little worry about the collateral damage to students attending public and non-profit institutions.

Myth #2:  States already provide superior oversight of out-of-state institutions offering online courses to students in their state.

Facts:  Most states do not regulate institutions who only offer 100% online courses to students in their state. SARA makes no such distinction, as it prompts review of an institution for initial SARA admission and review for annual SARA renewal. Additionally, SARA provides the student the ability to file a complaint in the institution’s home state, which has the most knowledge and understanding of the institution. Therefore, students who were previously not protected (because their state did not regulate an institution that served students only by online means) are now protected by SARA provisions.

Opinion:  Many of the states (MA, CA, NY, and WI) in which there has been opposition to SARA do not regulate 100% distance education activities offered by out-of-state institutions.  If the complaint is that SARA provides insufficient oversight, why aren’t these states regulating distance education of all out-of-state institutions?  SARA represents improved student protection in those states.National Council for State Authorization Reciprocity Agreements log

Myth #3:  SARA was developed solely by the colleges without any consumer protection advocates.

Facts:  SARA was developed openly in three phases:

  1. In 2010, Lumina Foundation funded the Presidents’ Forum and the Council of State Governments to develop a Model reciprocity agreement allowing states to acknowledge other states’ decisions in regard to institutional authorization. The Drafting Team included three state regulators, a former state regulator, a State Higher Education Executive Officers (SHEEO) officer with regulator duties, two regional higher education compact representatives, two institutional representatives, and a state legislator. Consumer protection was at the center of these discussions. Listening sessions were held with regulators, accreditors, and the higher education presidential groups. Drafts of the model agreement were widely circulated for public comment.
  2. In 2012, building upon the work of the Presidents’ Forum and Council of State Governments, the Western Interstate Commission for Higher Education (WICHE) advanced the next version of an agreement in collaboration with the other regional higher education compacts (Midwestern Higher Education Compact, New England Board of Higher Education, and Southern Regional Education Board). Drafts of proposed agreements were openly shared for public comment.
  3. In 2013, the Commission on the Regulation of Postsecondary Distance Education (chaired by former Secretary of Education Richard W. Riley) was created by SHEEO and the Association of Public and Land-Grant Universities. Many SHEEO offices include state regulators. After publishing a draft for open comment, in April 2013 the Commission issued its final report recommending SARA’s structure.

Opinion:  State regulators were involved throughout the processes. These regulators are the members of the consumer protection community most familiar with laws, regulations, and infractions surrounding state authorization oversight. In each phase, draft documents were openly shared and public comment was sought. The SARA development process started in 2010. While a few state regulators have opposed the idea of SARA all along the way, organized opposition is recent. There are now 37 SARA states and soon to be at least 40.  (See Why are objections arising so late in the process?  And why has SARA been so successful if it is so dismissive of students’ rights?

DC heros vs villains_RyanC

SARA requirements apply equally to both the “good” and “bad” guys. Photo Credit: Ryan C

Myth #4:  SARA should regulate the bad guys more than the good guys.

Fact:  SARA’s requirements apply to all institutions equally.

Opinion:  The good guys have nothing to worry about.

In a letter denouncing SARA, former Senator Tom Harkin (IA) opines: “For reasons that fly in the face of the philanthropic mission of the public and nonprofit institutions, the model act they helped draft actually forbids states from regulating differently based on sector. That’s right. Under SARA, Massachusetts is forced to regulate Harvard the same as it regulates ITT. If it doesn’t, then Massachusetts is kicked out of SARA and Harvard has to get approval from each state to offer online education. This is simply not the way it should work.”

That sounds logical until you realize that it is not just the for-profits that break the laws. Yes, there are for-profits that have committed heinous acts of misrepresentation and abuse. They should be punished.

In our work in the State Authorization Network, we have heard from large institutions with familiar names that are openly flouting state authorization laws. We have followed major state universities that have deceived and failed students by enrolling them in academic programs in licensure fields when the student could not practice in their state of residence. Small non-profit institutions can close the same way for-profits can—Burlington College did so last week.

Are transgressions by public and non-profit institutions less common? Probably. But how do you know who is going to become a bank robber until they rob a bank? The regulations should apply equally to all.

Myth #5:  The institution’s home state is the only state involved in the resolution of a student’s complaint.

Fact:  The SARA Policies and Standards Section 4 Subsection 2 provides the complaint process for SARA institutions. The process is more thorough than the myth indicates.  A student may appeal the decision arising from an institution’s own complaint resolution procedure to the SARA portal agency (the agency handling SARA matters) in the home state of the institution. The agency will then notify the portal agency for the state in which the student is located.  The resolution of the complaint will be through the complaint resolution process of the institution’s home state, but the states will work together to identify bad actors. Additionally, complaints are reported and reviewed by the regional compact to provide oversight of the state to ensure the state is abiding by SARA standards. This streamlines the line of complaint resolution and keeps the resolution within the laws of the state under which the institution applied to participate in SARA.

childs hands connecting the dots in coloring book.

Working together allows SARA to connect the dots & recognize patterns that would likely not be visible in a single state. Photo Credit: Camilla Nilsson

Additionally, this process allows NC-SARA to track any emerging patterns in student complaints and take swift investigative action if necessary. This is important as attorney generals in the states may be slower to act due to too few bad actors and little evidence of bad actions. SARA publishes quarterly on its website a list of complaints against colleges that have been appealed to the SARA portal agencies, while most states do not

Opinion: There is strength in states working together to identify and resolve student complaints and correct offending institutions.

Myth #6:  Student complaints can be resolved only by the laws and agencies of the institution’s home state.

Fact:  The SARA Policies and Standards Section 4 subsection 2 g. provides that there is nothing in the SARA Policies and Standards that precludes the state attorney general from pursuing misbehaving institutions that break state consumer protection laws.  Additionally, a violation of a federal regulation (such as that which rises to the level of a federal misrepresentation action) is still under the jurisdiction of federal authorities to pursue any actions against the institution.

Myth #7:  SARA requires student complaints be resolved by the institution. This is the same method that for-profit colleges use to hide complaints.

Fact: SARA follows a practice commonly used by states throughout the country that encourage students to exhaust local options before appealing to the next level. There is no requirement that the complaint remain at the institution. If an institution is stalling or not dealing with the student’s complaint and the institutional complaint process is not yet complete, that student still has the option to appeal to the appropriate SARA portal agency.

According to Section 4 (Consumer Protection) subsection 1 of the SARA Policies and Standards document: “Initial responsibility for the investigation and resolution of complaints resides with the institution against which the complaint is made. Further consideration and resolution, if necessary, is the responsibility of the SARA portal agency, and other responsible agencies of the institution’s home state (see the following section: Complaint Resolution Processes).” The student is expected to begin with the institution, but that is not the end of the student’s options.

Opinion: Again, the critics are confusing this provision with the actions of several for-profit institutions, which require students to sign mandatory arbitration agreements that foreclose their external routes to seek redress. Under pressure from the Department of Education and others, two for-profit universities recently decided to remove arbitration requirements from their enrollment agreements. Even if the for-profit institution requires mandatory arbitration, to remain a SARA member, the institution has to allow the student to use the SARA complaint process.

Myth #8: The purpose of SARA is to make it easier for the institution.

Fact: According to the Operational Principles of SARA, found in Section 2 of the Unified Agreement: “…the purposes of this Agreement are to:

  • Address key issues associated with appropriate government oversight, consumer protection, and educational quality of distance education offered by U.S. institutions.
  • Address the costs and inefficiencies faced by postsecondary institutions in complying with multiple (and often inconsistent) state laws and regulations as they seek to provide high-quality educational opportunities to students in multiple state jurisdictions.”

Opinion: Many institutional personnel also think that SARA is merely to make life easier for them. The primary purposes are listed in the first bullet. Without performing the regulatory requirements outlined in the first bullet, then any institutional benefits are not worth it.

Myth #9:  SARA won’t provide enough oversight to protect students from the bad practices of an institution like Trump University.

Fact: Trump University was a non-accredited and non-degree conferring institution that would never have been eligible to become a SARA institution. Per Section 3.2 of the Unified Agreement, an institution must have the following characteristics to be eligible to participate in SARA:

  1. Location: The institution is located in the United States, its territories, districts or Indian reservations.
  2. Identity: The institution is a college, university or other postsecondary institution (or collection thereof) that operates as a single entity and which has an institutional identification (OPEID) from the U.S. Department of Education.  This includes public, non-profit private and for-profit institutions.
  3. Degree-granting: The institution is authorized to offer postsecondary degrees at the associate level or above.
  4. Accredited: The institution is accredited as a single entity by an accreditation agency that is federally recognized and which has a formal recognition to accredit distance-education programs.
U.S. map showing the states that have joined SARA. Those that have not joined: California, Connecticut, Delaware, DC, Florida, Kentucky, Massachusetts, New York, North Carolina, Pennsylvania, South Carolina, Utah, and Wisconsin,

As of the publishing of this blog post (May 25, 2016), 37 states have been accepted into SARA. More to come soon.

Myth #10:  Institutions will shop for the lowest-regulated state or use back door acquisitions.

Facts: According to the Roles and Responsibilities of Participating States, found in Section 5 of the Unified Agreement, each state joining SARA must agree that this agreement has the capacity to perform several tasks, including:

  • “It has adequate processes and capacity to act on formal complaints…”
  • Demonstrate that consumers have adequate access to complaint processes.
  • Ability to document complaints received, actions taken, and resolution outcomes.
  • Notify institutions and (if appropriate) accrediting agencies of complaints filed.
  • “It has processes for conveying to designated SARA entities in other states any information regarding complaints against institutions operating within the state under the terms of this agreement, but which are domiciled in another SARA state.”
  • “It has clear and well-documented policies for addressing catastrophic events.”

Opinion: The purpose of SARA is to establish a common baseline for regulation of interstate activity. It does the institution no good to shop for the lowest-regulated state, as the bar is set at the same height in all states. If a state is somehow shirking its duties, SARA gives other states leverage to pressure them to meet their responsibilities.

Myth #11:   SARA will require institutions to accept transfer from other colleges.

Facts:  Transfer is not a part of this reciprocity agreement. As stated in the opening paragraph of the SARA Policies and Standards, SARA is an agreement “that establishes comparable national standards for interstate offering of postsecondary distance-education courses and programs.”   The focus is on the activities offered in other states to students of the institution.

Myth #12:  There is a better reciprocity option through the “Interstate Distance Education Reciprocity Agreement” between Connecticut and Massachusetts.

Fact:  Although a reciprocity model was offered by a critic of SARA in a recent letter to the New York State Commissioner of Education, this model does not appear to exist.  Research of legislation in each of these states, review of each state’s higher education websites, review of the State Higher Education Executive Officers Association (SHEEO) Surveys maintained by each state’s higher education agency, consultation with institutions in each state and a direct request to the Connecticut Office of Higher Education lead us to the same conclusion.  There is no Interstate Distance Education Reciprocity Agreement between Connecticut and Massachusetts.

There have been papers published by SARA critics suggesting what a “good” reciprocity agreement might include. They always end with allowing each state to essentially take any actions it wishes to take regarding an out-of-state institution. That’s not reciprocity. That’s the current state of affairs that so poorly serves students and institutions alike.

Meanwhile, Connecticut’s legislature has just passed legislation allowing it to join SARA.

In Conclusion…

The sharing of critical analysis of the State Authorization Reciprocity Agreement is healthy to provide states, institutions, lawmakers, and citizens the ability to assess the pros and cons of this new process.  However, to publicly report an analysis that fails to show completed research or understanding of the language of the Agreement is a disservice to the states, institutions, lawmakers, and citizens.   Please review the Unified SARA Agreement and the State Authorization Reciprocity Agreement Policies and Standards before making any judgments about the viability of SARA.  We hope that the presentation of the publicly reported “myths” and corresponding facts will aid your ability to make an appropriate judgment.

In Disclosure…

In this era of ad hominem attacks we have focused on the statements that we feel are erroneous or misleading and not the personalities involved. In case you wonder why we care about these issues, here is a brief background about the two of us:

  • Russ Poulin served on the original drafting committee and the WICHE committee that developed the language that became SARA. Every discussion in those meetings took the student protection responsibilities very seriously. I developed the WCET State Authorization Network to help institutional personnel navigate and comply with each state’s regulation.
  • Cheryl Dowd is a former institutional compliance officer who now directs the WCET State Authorization Network, which serves more than 75 members encompassing more than 700 colleges and universities.

While others in higher education circles have merely railed against any type of regulation, we have been consistent in trying to find a balance that meets the needs of parties, regulators, institutions, and consumers.


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


Dowd-CherylCheryl Dowd
Director, WCET State Authorization Network
WCET – WICHE Cooperative for Educational Technologies


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