Lights, Camera, Action! – Developing Faculty in 20 Minutes

Change begins with an idea, and in the Instructional Design department at Walters State Community College, we are not afraid of change. We realize that technology is changing our world minute by minute, and by embracing that movement, Walters State continues to be on the cutting edge of the current technology allowing us to offer new and innovative ways to make teaching and learning more effective for our faculty as well as our students.

Walters State Community College Homepage

Walters State Community College is “a learning-centered, comprehensive, public community college dedicated to increasing educational attainment and supporting economic development by providing affordable, high-quality educational opportunities for the residents of East Tennessee.”  We strive to be a leader in the educational arena by discovering new and innovative ways to not only assist our own faculty and students’ educational needs, but we also strive to support others that are outside our four campus community as well. Thus, the idea for the 20 Minute Mentor was born.

Walters State Community College - The 20 Minute Mentor homepage

What is the 20 Minute Mentor?

Every Tuesday morning at 9:30 am, Darlene Smith of our Instructional Design department broadcasts a live 20 Minute Mentor session using the free Periscope app and shares inventive ways WSCC is using technology. Darlene contacts faculty members who are effectively using mobile learning in the classroom, and schedules times to spotlight them on the weekly broadcast. Well in advance of the scheduled date, Darlene and the faculty member plan a rough outline for the broadcast so the session runs as smoothly as possible. Some of the broadcasts happen in a classroom, while others are just a one-on-one sessions with faculty members at different locations on campus. Both ways have been effective, per feedback from Darlene’s Periscope viewers. The viewers have the option of viewing live, but because the weekly broadcasts are published to a YouTube channel, viewers can replay or watch the broadcasts at a more convenient time on the 20 Minute Mentor mPage.Periscope icon

What is Periscope?

Periscope is a live streaming video app. It enables users to “go live” via a mobile device (Smartphone, iPad, etc.).  It allows “on the go” broadcasting, streaming video and audio to viewers who join the broadcast. The user sets up a Periscope account using a Twitter handle. During the broadcast, viewers can engage in real-time discussions, ask questions, and provide feedback using the “Say Something” field at the bottom of their screens. All live videos are uploaded to Twitter and remain active for 24 hours; videos can also be saved to the camera roll so the broadcaster can publish them at a later date.As you can see, Periscope definitely has many uses both inside and outside the classroom.

What lessons have we learned?

Our 20 Minute Mentor series began in the spring semester. February 23, 2016 was our first live broadcast, and the last broadcast for the spring semester was May 10, 2016. During that time, we have learned some valuable lessons.

First, have a strategy. Develop a plan by asking yourself some simple questions:

  1. What are your goals? Planning is crucial to a successful live broadcast. Decide what you want to accomplish. Determining your goals will keep you focused on your purpose. Remember, “If you fail to plan, you plan to fail.”
  2. What day(s) and times are you going to broadcast? Being consistent with a day and time is a must for a successful broadcast. Oprah Winfrey was on every afternoon at 4:00 pm EST, Monday through Friday. To watch her, viewers had to be near a television at that time. We all know her show was a success, and she had a faithful audience. By being consistent with the “channel” days and times, viewers know when to have their mobile devices ready to watch.
  3. What topics do you want to discuss? Do you want to introduce a weekly web tool or app? Do you want to spotlight what is happening on your campus or in your department? Do you want to provide a “Study Hall” for students to get additional help outside of class time? Do you want to provide “How to …” broadcasts for incoming students and their parents? Deciding the topics ahead of time will help you stay organized. After deciding on the topics, create interesting titles for each. You definitely get more viewers with “catchy” titles for your broadcasts!

Second, be consistent. Jumping on Periscope every now and then will not have the impact that a consistent day and time will have. Yes, it will be fun, but it won’t grow your audience base because they won’t have time to make plans to “be there.”

Third, keep trying. Remember that Periscope is a social media platform, and with any social media platform, you have to keep using it in order to grow it. Below is a collection of data for WSCC’s 20 Minute Mentor series.

20 Minute Mentor list of topics, dates recorded, and number of viewers.

As you can see from the data above, the number of viewers fluctuated from week to week, but 609 viewers were introduced to innovative technology ideas that are being implemented on the Walters State Community College campuses. We feel that number is acceptable for our trial run of live broadcasting. We are looking forward to comparing the data from spring 2016 with the fall 2016 semester which ends in December. We will keep you posted of our outcomes! Bottom line, you may not see quick results, but over time, you will make an impact!

Finally, just have fun! David White, Assistant Dean of Distance Education and Instructional Design at WSCC reminds us often that “Sometimes good enough is good enough.”  Do a few practice runs with Periscope to get comfortable when broadcasting, but relax and have fun! Per our experience, you will be far more critical of your broadcast than your audience will.

WSCC is most proud that the broadcast uses a free app, that the person with the vision for this professional development topic is one of our own faculty members working in Instructional Design (Darlene Smith; @darlenesmithws), and that Darlene also leads the Mobile Learning Academy 1.0, 2.0, and 3.0 and, therefore, knows all the faculty involved as potential presenters in the “20 Minute Mentor.” Darlene has been able to follow the presenters who have gone through her Mobile Learning Academies and has then been able to assist their growth over time as faculty using mobile learning in their classrooms and, later, as faculty training other faculty members. In addition, by having the one keystone person leading training of faculty and spotlighting faculty using mobile learning, WSCC has captured what we have produced internally and have been able to showcase it around the world to anyone with a mobile device and an interest in mobile learning.Darlene Smith and David White

Darlene Smith
Associate Professor of Education

David White
Assistant Dean of Distance Education and Instructional Design and Professor of English

Research on Distance Ed and Technological Advancements: An Update on DETA

What’s Been Up?

The National Research Center for Distance Education and Technological Advancements (DETA) is wrapping up its second year of a national U.S. Department of Education funded effort to conduct rigorous research to identify key factors influencing student success in blended, online, and competency-based education.

The DETA Research Toolkit was launched in 2015 intended to help overcome the lack of research literacy in distance education practice and the methodological disciplinary DETA Logo reads "DETA Research Center"divisions by providing a common language for educators to conduct research. It contains guides on designing experimental and survey research, support for data collection through institutional warehoused data and student surveys, a student survey instrumentation packet for dozens of meaningful measures, data codebooks to facilitate merging of data sets, and more. Notably, the DETA Research Toolkit has been downloaded by almost 600 individuals in every state of the U.S. and in over 20 countries throughout the world in less than a year.  These research tools facilitate cross-institutional empirical data collection examining students, courses, programs, and institutions to identify instructional and institutional practices that influence student outcomes, in particular for underrepresented students.

As shared on the WCET Frontiers blog last fall, DETA Subgrant Awards included a competitive proposal process to identify and fund faculty and institutional partners to employ these research designs to address top questions in distance education as outlined in toolkit. These top research questions were developed at a national summit held last year bringing 50 experts from across the country to guide the DETA research agenda.  Since last fall, several institutions have partnered with DETA to conduct research at their institutions, including Oregon State University, University of Central Florida, California State University Fullerton, Milwaukee Area Technical College, Florida SouthWestern State College, San Diego Community College District, Montana State University, and WCET.  Each of these institutions collected student data in survey or quasi-experimentally designed studies in the Spring 2016 semester and completed preliminary analysis over the summer months.  Several were part of cross-institutional studies. With a good foundation of national research, we look forward to bringing on several new partners this fall.

What’s Coming Up?

We still have several studies in which we are looking for institutional partners for a fall data collection.  Interested in being a DETA Partner? The data collection consists of DETA gathering institutionally warehoused data, most likely from your student information system, and the administration of a survey to your blended, online, or competency-based education students. Please complete this form to show your interest.

We are working on preparing a series of DETA Research Briefs and DETA Webinars to help share the findings of our research. The research briefs will be 2-page documents that contain an abstract, introduction, methods, results, and conclusions.  The webinars will go into much more detail explaining the university or college demographics, particulars about their online courses and programs, description of the intervention, if applicable, recommendations for future research, and implications for practice.  This series will be coming later this fall.

We are putting together a special edition of the Online Learning Journal of DETA-supported research that will be released in 2017. The special edition will contain 8 peer-reviewed journal articles highlighting DETA research designs. Each article will discuss implications for future research and practice.

We are looking to release DETA Research Toolkit 2.0 this fall.  We are currently looking for contributors and reviewers. Feel free to email us to express your interest.

Tanya Joosten in front of a screen that reads "if we knew what we were doing, it wouldn't be called research. - A. Einstein"

Tanya Joosten explaining DETA’s research agenda and the Toolkit.

Learn More about DETA at the WCET Annual Meeting

Join the DETA Community in Minneapolis! We will be at the WCET Annual Meeting next month holding sessions to bring folks together, share research, and discuss challenges and opportunities in conducting research in an effort to build a community to increase awareness of research being conducted, build collaborations in research and funding, and support each other in conducting rigorous research. If you are interested in attending our sessions, helping facilitate a session, or presenting at one of the sessions, check out more details. There will be primarily 3 sessions that you can attend:

  1. A workshop: Creating and Diffusing Online Instructional & Institutional Practices From Data & Evidence. With a goal of discovering how we turn our research findings into practice, this workshop is a roundtable brainstorming discussions that takes findings from a cross-institutional study and challenges the participants on determining how to interpret these findings, turn them into practice, and develop diffusion processes across the institution.
  2. A lightning round session: Research in Distance Education and Technological Advancements (DETA) (Part 1/2).  With a goal to increase everyone’s awareness of research being conducted, we will hear from awardees and others who are conducting research in distance education at their respective institutions. Each researcher will briefly describe their study in a lightning round format of 5 minutes and 5 slides per presenter.
    Note: If you are interested in presenting, please contact DETA via email. We encourage all folks conducting research no matter how big or how small to come share.
  3. A small group discussion: Research in Distance Education and Technological Advancements (DETA) (Part 2/2).  With a goal of better understanding how DETA can support research in this area, participants will gather in small groups to discuss a) challenges in conducting research and needs of the research community, b) possible solutions or resources to meet needs and overcome challenges, and c) opportunities for funding and collaboration. In previous DETA community discussions, we identified some of the top challenges in conducting research. We have been working to identify and implement recommendations to  increase each individual’s and institution’s capacity to carry out DETA Research. Come ready to ask questions, pose problems, brainstorm solutions, share opportunities for funding or collaboration, and more!

Tanya Joosten, PhD
Director, eLearning Research and Development, Academic Affairs
Co-Director, National Research Center for Distance Education and Technological Advancements
University of Wisconsin-Milwaukee

The Fun of Minneapolis and #WCET16

WCET’s 28th Annual Meeting is a mere seven weeks away- October 12-14.  In no time, our community of edtech leaders and innovators will convene in beautiful Minneapolis to connect with colleagues,  exchange ideas,  and share triumphs and challenges. The WCET program is a blend of extended sessions which provide a deep dive into emerging issues, panel sessions, facilitated discussions, and networking events.  Make the most of your time at #WCET16 and in the scenic urban oasis of Minneapolis.

Minnehaha falls_ Evan Miles

Minnehaha Falls, Photo Credit: Evan Miles, flickr

WCET Activities at the Meeting
Here are a few ways to enhance your conference itinerary:

Minneapolis Highlights

Betcha don’t get to go to Land of 10,000 Lakes, very often, doncha know.  Try and achieve as many of these as you can and Tweet it with #WCET16.

We look forward to seeing you in Minneapolis in October.  If you haven’t registered yet, do so before the early bird registration rate expires on September 9. Join us.

Megan Raymond headshotMegan Raymond
Assistant Director, Programs and Sponsorship
WCET – WICHE Cooperative for Educational Technologies
mraymond@wiche.edu@meraymond

 

Nine Organizations Partner on Official Comments for State Authorization Regulations

Nine higher education organizations partnered to submit comments to the Department of Education regarding its proposed state authorization regulations for distance education. By working unison, we provided a strong and consistent single voice in making recommendations to the Department.

The Partners

Contributing to the letter are six distance learning associations with total memberships of over 1,000 institutions:

We were pleased to be joined by the following partners who provided additional expertise and perspectives:

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

The letter indicates support for many of the recommended regulations. All of the partners support increased information for students and improved consumer protections. Some of the proposed regulations need clarifications for institutions to understand how to comply. Other proposed rules simply fall short in meeting the Department’s own goals.

Our comments focused on:

  • While the Department recognizes reciprocity as a means for an institution to obtain approval in a state, they want to assure that all state can still enforce their consumer protection laws. SARA allows states to enforce “general-purpose laws” that are applicable to “all entities doing business in the state, not just institutions of higher education.” The Department’s definition of “consumer protection” should mimic SARA’s or states could define it too broadly.
  • State Complaint Processes. Institutions would be denied offering aid in states without a complaint process that meets Departmental requirements. Apparently, the expectation is that out-of-state institutions will: a) know which states are out-of-compliance, b) lobby those states to change their process, and c) hope that they are lobbying for change that meet the Department’s needs. While we support all students having a reliable route for complaints, this process simply will not work. We suggest alternatives
  • Professional Licensure Notifications. The Department substantially underestimated the time for institutions to comply and the ability of state agencies to respond. A delay in enforcement time is needed
  • “Adverse Actions” Notifications. Much clarification is needed as the types of actions differ greatly by accrediting and state agencies. We also recommend that institutions be required to report actions “taken” not actions “initiated.” The latter is often an investigation that does not result in negative consequences for the institution.

Thank you to all our  partners who provide great advice and support throughout the process.

WCET and SAN Comments

We also submitted a second set of comments that reflected the interests of the WCET State Authorization Network (SAN) members. We expressed support for the issues (listed above) that were raised in the joint letter. We also included several requests for clarification that were submitted by WCET SAN members. They had very good questions about the meaning of some terms or how they might be enforced.

What’s Next?

The Department will consider the comments and has said that it will issue a final regulation by the end of the calendar year. If the final regulation is released before November 1, then the regulations become law on July 1, 2017. If they wait until November or December, then they become law on July 1, 2018. At its discretion, the Department may announce that it will delay enforcement of parts of the regulations until a later date.

Bottom Line

If you are not in compliance as an institution or for your professional programs in a state in which you wish to enroll students, don’t hesitate to do so. Avoid the rush. You could get trampled.

The state regulators or licensing boards have no incentive to hurry your application to meet a federal requirement. They do all they can, but they often have minimal staffing.

Happy authorizing!!Cheryl Dowd

Cheryl Dowd
Director
WCET State Authorization

 

 

Russ Poulin

Russ Poulin
Director, Policy and Analysis
WCET – WICHE Cooperative for Educational Technologies

 

Support our work.  Join WCET.

North Dakota Open Educational Resources Initiative: A System-wide Success Story

Overview

The North Dakota University System Open Educational Resources Initiative is a 3-phased plan hinging upon a unique collaboration among the North Dakota legislature, the University System Office, and the faculty at public institutions across the state. At the intersection of these three entities are change leaders who have come together for a common goal of improving higher education by reducing textbook costs for students. A 2015 post previewed this work, and this post outlines the plan, the people, and the product.

Project Inception

The American public has called for a change.  Higher education is expensive and the national student debt load is collectively around $1.3 trillion. Lawmakers and educators in North Dakota are interested in ideas that might reduce the cost of attendance at ND public institutions. During the 63rd Legislative Session, Thomas Beadle, a young representative, sponsored a legislative study and resolution urging the North Dakota University System to increase the use of open textbooks as a way to cut costs for college students. In 2013, the Legislative council estimated that North Dakota students spent around $1,100 per year on textbooks. Rep. Beadle described how the idea came about:

“Going into the 2013 legislative session, I really wanted to focus on our students and how we can try to look at new ways of helping them.  For years we have been talking about the growing levels of tuition and fees, but we hadn’t done anything that looked at the other costs associated with going to school.  As a young, recent college grad, I remember how frustrating it was to have to buy hundreds of dollars’ worth of books each semester, and only be able to get a fraction of that cost back when I would try to sell them later on.  I knew that the internet and technology was changing the game in how content was being delivered, but I hadn’t been seeing it on my campus, and knew that as a state we could do better.”

Representative Thomas Beadle of the North Dakota State Legislature.

ND Rep. Thomas Beadle

“In collaboration with some friends of mine, who had faced very similar frustrations about rapid cost increases for books and ‘silent expenses’ that went in to their education, we came up with Open Textbooks as being a first step for North Dakota to look at in order to try and help the students of the state not only save a few dollars, but also to help them get a more active learning tool.”

“While I knew about Open Textbooks and the impact that they could have, the whole world of Open Educational Resources was very foreign to me.  Fortunately, we had Dr. Spilovoy, a very visionary leader in the ND University System who would take our resolution pushing the NDUS to explore this new technology and run with it.  When I introduced the concept, and got legislative approval, I had hoped to start a conversation and try to move the ball forward a little bit.  I hadn’t expected the tremendous snowball effect that it would create!”

Gaining Funding and Support

In order for a system-wide initiative to succeed, there had to be stakeholders involved at every level. A bipartisan and student-focused group of legislators on the Interim Higher Education Funding Committee supported the idea and provided a platform for innovation and feedback. The North Dakota University System put together a team made up of faculty, a student, technologists, and provosts to draft a white paper exploring the concept of open textbooks in response to the legislative request. Because I work with Academic Affairs and Technology at the NDUS system office, I was on the team that wrote the white paper. And after the legislative session, I was asked to lead the Open Educational Resources Initiative for NDUS. Over the next few months, I spent a significant amount of time researching, planning, and preparing presentations, and collaborating with stakeholders across the North Dakota University System.

Governance, cost, collaboration and policy considerations were paramount to the planning process. I wanted to find and partner with a repository of open education materials instead of having to create and maintain a library. The University System is built on the concept of academic freedom. Faculty own the curriculum and choose materials for the courses they teach. I knew that faculty development, support and buy-in were key to the success of the project. An effective approach would be to empower campuses to create and implement open educational resources and textbooks in a way that best suited their unique mission, vision, and faculty. Finally, I knew that funding would be necessary and that the legislature would be interested in seeing a return on its investment. I put together a project concept and presented it at the Interim Higher Education Funding Committee.A picture of a stack of textbooks

OPEN EDUCATIONAL RESOURCES PARTNERSHIP CONCEPT:
Improving Student Access, Affordability, and Academic Success

Textbook costs create a financial burden on college students that can impact their academic success and their financial health. North Dakota University System students each pay an estimated average of $1,100 per year for academic course textbooks. Open textbooks and other open educational resources can help alleviate the burden of textbook costs and reduce the cost of attendance. Open textbooks are complete, real textbooks that are licensed to be freely used, edited, and distributed. Open educational resources include peer-reviewed videos, simulations, lesson plans, and many other openly licensed materials.

By replacing traditional textbooks with open textbooks and open educational resources, the cost of attendance would be reduced without impacting the budget of the college or university. And faculty would have the opportunity to adopt open textbooks and educational materials that they can edit to best meet the needs of their students.

Concept Overview: Implement a system-wide Open Educational Resources initiative throughout North Dakota University System in three phases:

  • Phase 1. Partner with the Open Textbook Network and the University of Minnesota Open Textbook Library to build on proven success. Expand to other Open Educational Resources opportunities that would benefit our students and faculty. Phase I will introduce open textbooks to faculty with support, professional development, and stipends.
  • Phase 2. Train a trainer at each campus so that the campuses begin taking ownership to reduce textbook costs for students. NDUS would also host an Open Educational Resources Summit.
  • Phase 3. North Dakota Open Educational Resources Ideation Grant. Campuses would be challenged to design and implement their own campus-wide open educational resources initiative. Funded proposals will include support and collaboration from campus administrators, faculty, technologists, and others on campus. Proposals can include a variety of peer-reviewed open educational materials such as open and/or digital textbooks, videos, simulations, and other resources that replace traditional textbooks and reduce cost of attendance for students. Campus proposals will be funded based on actual dollars saved in student textbook costs.

The Report Prompts Legislative Action

The work between sessions set the stage for successful implementation. And in the 64th Legislative session, Representative Thomas Beadle introduced legislation to fund a project to increase the use of Open Educational Resources. The governor and legislature supported the project with funding even though overall budgets had been cut state-wide. The final budget appropriation was $110,000.

Of the legislative appropriation to support the Open Educational Resources Initiative, Rep Beadle said, “One of the benefits of a state like North Dakota, is that we are a small community.  While that can be seen as a limitation by many, it has actually helped us experience rapid success.  We are small enough to be nimble and adapt quickly. Every stakeholder knows that they need to work with others in order to get things done, and we need to develop and foster relationships to get things done well.  We have really created a strong team atmosphere that is working together to push OER in North Dakota, and to make this a success for our students, our institutions, and our state.  The buy-in and leadership we have seen on our campuses within the faculty has been tremendous, and the assistance provided by our University System office has been crucial.  As a lawmaker who is responsible to the citizens and the taxpayers, being able to see the return on investment has been crucial.  Knowing that we have the players and stakeholders all seeing benefits, and seeing ways that we can improve and operate more efficiently, has allowed us to be able to get legislative support for these initiatives, and hopefully to continue to provide that support in the future.”

Data Shows Progress

In order to show progress, cost savings, and project success, I began working on baseline project data. In 2013, Babson Survey Group released “Opening the Curriculum: Educational Resources in U.S. Higher Education, 2014.” I contacted Dr. Jeff Seaman of Babson Survey Group and asked if we could collaborate on a survey report comparing ND’s baseline data to the national survey data. He responded positively, and by October, 2015, we released “Opening Public Institutions: OER in North Dakota and the Nation, 2015.”Report cover. The title of the Report is "Opening Public Institutions: OER in North Dakota and the Nation, 2015" by Tanya M. Spilovoy and Jeff Seaman. The logos at the bottom of the page are for the Babson Survey Research Group and the North Dakota University System.

Key findings from the report include:

  • NDUS faculty are more aware of open educational resources than their counterparts nationally.
  • Similar to their peers nationally, NDUS faculty are taking the initiative with OER adoption. NDUS faculty report similar barriers to adoption; however, they also report that they are currently using a variety of OERs for instruction (primarily videos).
  • More than half of NDUS faculty and those at national public institutions report that they are not sufficiently aware of OER to judge its quality.
  • The most significant barrier to wider adoption of OER remains a faculty perception of the time and effort required to find and evaluate it.
  • Faculty are the key decision makers for OER adoption. At the two-year Associates level, North Dakota University System faculty enjoy significantly more autonomy in the selection of course materials than their peers who teach at the associates level at public institutions nationally.
  • A majority of North Dakota University System faculty say that they “will” or “might” use open resources in the next three years.

Project in Motion

The NDUS joined the Open Textbook Network and began collaborating with other partner institutions already implementing open educational resources projects. I assembled a NDUS OER Steering Committee made up of a student representative, faculty members from each institution type, a legislator, and national experts in open education.  In October, 2015, I organized a system-wide Open Educational Resources Summit at Valley City State University. Provosts were asked to send campus OER leadership teams made up of innovative faculty, librarians, instructional designers, and open-minded individuals. David Ernst, Ph. D., the Director of the Center for Open Education and Executive Director of the Open Textbook Network spoke and conducted a faculty workshop on open education and the adoption of open textbooks. Faculty that reviewed an open textbook from the Open Textbook Library and wrote a peer review received a $250 stipend.

The NDUS Open Educational Resources Campus Grants Call for Proposals was announced. Campus teams left the NDUS Open Educational Resources Summit energized to create their own campus plans and submit for funding.

Return on Investment

On March 4, 2016, the OER Steering Committee met to review campus OER project proposals and give feedback. The initial state investment was $110,000. The first four funded proposals include estimated student cost savings of more than $2 million for school year 2016-2017.  Three of the campus projects will provide faculty stipends to revamp general education courses using open source materials and textbooks. One project at the University of North Dakota will make Robinson’s “The History of North Dakota” an open textbook. Another round of grant proposals is due in October, 2016 with four more $10,000 institutional grants anticipated.

The final financial impact of this initiative will be calculated at the end of the 2017 fiscal year. In the words of Senator Tim Flakoll, Chairman of the Senate Education Committee, “The Open Educational Resources Initiative could well go down in history as having the highest return on any higher education investment we’ve made in the last 25 years.”

___________________________________________________

Call for Proposals: NDUS Open Educational Resources Special Projects

The North Dakota University System seeks grant proposals that implement high-impact, collaborative projects in support of open education and reduced textbook costs for students.

Applications for any amount of funding up to $10,000 are welcome from North Dakota University stakeholders, including faculty, librarians, technologists, administrators, students, and bookstore staff. Projects must involve the creation, adaptation or innovative use of Open Educational Resources (OER), which are educational materials that are openly licensed to the public to freely use, adapt, and share.

Sustainable adoption of OER is a complex issue with many parts, including course redesign, open material reviews, technology support, curriculum mapping, and much more. Project proposals will be evaluated using a rubric that balances the following criteria to prioritize impact and collaboration:

  1. Student savings on textbooks.
  2. Quality considerations such as use of peer reviewed resources, attribution/copyright clearance, and ADA compliance.
  3. Serving a campus or discipline where the availability or use of OER is underrepresented
  4. Collective commitments, such as:
    1. Department-wide commitments (for example, redesign all sections of a class, or all classes in a sequence), or
    2. Multi-institutional commitments (for example, collaborators on more than one community college campus, commitment to implement at more than one campus, or a 4-year partner).
    3. Institutional in-kind (e.g. release time) or cash match commitments (not required but may be considered favorably during the review process).
  5. Assessment plan to demonstrate improved student savings, learning, retention, and success.

Completed proposals should be no longer than three well-written pages and signed by the applicants and supervisors. The OER Steering Committee anticipates making 5-10 awards. Proposals are due 5 pm Monday, February 29, 2016. The NDUS OER Steering Committee will notify applicants by 5 pm Thursday, March 31, 2016.

___________________________________________________

Tanya’s Tips and Take-Aways

  1. Focus on Students. When leading an Open Educational Resources project, focus on making a difference for students. It is motivating to think that more people will have the opportunity to access information, and that students won’t have to go into more debt because of high textbook costs. Student associations and leaders will be excited to help promote an Open Educational Resources Initiative.
  2. Empower the Faculty. Faculty rarely get to showcase the amazing things they do in their classrooms because they are busy focusing on and teaching students. Make faculty the super stars when talking about Open Educational Resources. Ask expert faculty to talk about how they’re using open textbooks and resources in their classrooms. You will be amazed what you’ll learn from faculty. Faculty appreciate sharing ideas and collaborating. And remember that they are the experts in their field; faculty are the keepers of the curriculum.
  3. Collect the Data. You need to show a return on investment. Collect baseline data on student textbook costs, faculty needs, barriers to adoption, and faculty understanding of Open Educational Resources and textbooks. At the culmination of the project, collect follow-up data so that you’ll be able to show growth, improvement, and textbook cost savings.
  4. Customize the Message. There are many reasons why replacing high-cost textbooks with free textbooks and resources makes sense. However, different groups of stakeholders care about different things. Customize your presentations and message to reflect what folks care about. Faculty are interested in protecting academic freedom, having the autonomy to choose and customize resources, adopting quality learning materials, and helping students meet the course objectives. Talk about how OER can meet faculty needs. Legislators and administrators are interested in initiatives that will be successful and reflect positively on their state and institutions. They want to see a good return on any monetary or time investment. Remember that legislators and administrators are also parents, neighbors, and friends; everyone cares about education. Students are interested in saving money, being engaged, and the convenience of accessing learning materials in a variety of formats on any device. All of these viewpoints are valid, and you’ll find great success if you focus your presentation on what matters to the audience.
  5. Find your People. There are innovative, excited, supportive people who are interested in improving higher education. Spend time with them and absorb their energy. Listen to their ideas; ask what they think of your ideas. Give them credit when they help you. All along this journey, there have been people who have opened doors, offered encouragement, and signed on the dotted line because they believed in it. There will also be people who hate change, and/or dislike you. There might even be folks who actively work to stop or sabotage your project. That’s ok. You don’t need to waste time trying to change them or fight about it. Think of them as part of the adventure. Smile, be polite but firmly state you will continue the work, and then find a pathway around their roadblocks. I’ve discovered that many of the people who initially resisted the project are now actively working to promote it. Focus your time and energy on the people who will contribute to the project’s success. Keep your eyes on the prize, and never give up on your goal.Tanya Spilovoy

 

Tanya M. Spilovoy, Ed. D.
Director, Distance Education and State Authorization
North Dakota University System
Tanya.spilovoy@ndus.edu

Questions about EQUIP, Ed Department’s Expansion of Aid to New Providers

On Tuesday, The U.S. Department of Education announced (Department press release, Wall Street Journal story) the eight partnerships that were selected in the EQUIP (Educational QUality through Innovative Partnerships) experimental sites program. The Department sought collaborations between accredited institutions that offer federal financial aid and newer providers who were previously not eligible to offer aid. The ultimate goal is to help low-income students use federal aid to earn credentials that will quickly earn them employment.

The experimental sites program allows the Department to wave some (but not all) aid regulations. For the purposes of this program, waived was the ceiling of no more than 50 percent of the education in a certificate of degree program being offered by an “alternative provider.” Even with the waiver, the non-accredited provider would need to partner with an accredited college.students at graduation sit attentively with their tassles still on the left side of their mortar boards.

The Eight Programs Chosen

The chosen participating collaborations represent a mix of programs. While about half of the credentials are focused on computer programming, there is an attempt in some of the remaining projects to go beyond training programs that lead to obtaining only a narrow set of vocational skills.

I’m also glad to see five WCET members being chosen to participate. Accredited institutions include Colorado State University-Global Campus, Dallas County Community College District, and Thomas Edison State College. StraighterLine is a non-accredited provider and Quality Matters is serves as a Quality Assurance Entity (QAE).

WCET’s Involvement

As you may recall, WCET helped to disseminate information about the program last fall. Together with the Community College of Denver, we hosted an in-person question and answer session with David Soo, who runs the program for the Department. We will have a session on the EQUIP program at the WCET Annual Meeting in October in Minneapolis. Please join us!

Questions

The Department has initiated several experimental sites programs in the past few years and they should be applauded for beginning to expand their horizons. While I understand that the program is just beginning, I do have some questions (or comments disguised as questions) about the program and what may come of it.

  1. How will we apply what we learn from the varied quality oversight models used?
    Each project is required to engage a Quality Assurance Entity (QAE) to address a very long list of quality oversight questions. Given that this is an experimental program, an extensive set of metrics was needed. There are a wide variety of agencies. Given the attack (sometimes fair, but almost always overstated) on accrediting agencies, it will be interesting if higher education can find some new models that might work.
  2. What will be the role of the accrediting agencies?
    The accrediting agencies seemed to be only tangentially included. Will some insert themselves into the process more aggressively than others?
  3. Who is responsible for consumer protection? What will be the role of the state oversight agencies?
    There might be two oversight agencies that oversee the activities of this collaboration. By federal regulation, the aid-granting institution must have a state agency that receives complaints and acts upon those complaints. Many states have agencies that oversee non-accredited businesses that offer vocational training or non-credit instruction. In those states, there are those in the “alternative provider” world that have chosen to ignore the regulators and/or declare themselves exempt (even if they are not), or tell students that they have all the proper approvals (even if they do not). On this, I twice contacted one provider and was assured that all was fine in a state in which I knew they were out-of-bounds. At a recent Departmental gathering, one well-known leader of such a company declared that “my only accreditor is the marketplace.” That’s great for the business and is valid for his business. This is bad news for students. (Caveat: I do NOT mean to paint all alternative providers with the same negative broad brush. As with anyone offering education, there are the good and the not-so-good.)
  4. Could someone explain to me the whole “for-profit” relationship with the Department?
    On the one hand, there is this (often justified and recently intensified) vehemence toward the for-profit higher education sector. On the other hand, Marco Rubio, Hillary Clinton, and some in the Department have doubted the ability of traditional higher education to meet societal (again some justification there) and have touted a new set of for-profits as the saviors.
  5. When will Congress give the Department more leeway to be even more creative?
    The Department could not set aside all regulations for the experimental sites program. For example, adherence to the “regular and substantive interaction” regulation probably kept away some MOOC and adaptive learning providers. In the next higher Education Act, can the Department get even more leeway to waive regulations on an experimental basis?
  6. If “regular and substantive interaction” had to be enforced, how did a correspondence program make the cut?
    The Department’s Office of the Inspector general wants the Department to crack down on aid to programs that don’t meet their interaction definition. How will this one project comply?
  7. What’s in it for the colleges? Won’t it make sense to let the providers give their own aid?
    That’s a long-term question.

In Conclusion

Innovations SHOULD raise questions as they are exploring unfamiliar territory. I fully support the program and eagerly await the lessons to be learned.

RussRuss Poulin holding a baseball bat.

Russell Poulin
Director, Policy & Analysis
WCET – The WICHE Cooperative for Educational Technologies
303 – 541 – 0305
rpoulin@wiche.edu

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Why We Need to Stop Using ‘Self-Paced’ in CBE Descriptions

Myk Garn is a long-time friend of WCET. He currently champions “new learning models” for the University System of Georgia. Myk also serves on the Board of Directors for the Competency-Based Education Network (C-BEN). After recent discussions about attacks on the CBE model (see last week’s Department of Education’s Office of Inspector General’s criticism on the accrediting agency WASC’s handling of CBE), WCET invited Myk to share this opinion. You will be hearing more from WCET about the attacks on CBE in the coming weeks and months. Thank you, Myk.
Russ Poulin

In competency-based education (CBE) ‘the time it takes to demonstrate competencies varies and the expectations about learning are held constant,’ (CBEN, 2016).  This paradigmatic shift predicates momentous opportunity for accelerated learners who can progress through programs more rapidly ¾ AND ¾ for learners who need extended time to achieve mastery.

BUT — (and this is my kvetch) — there is a problem with a key phrase used to describe the time — and control over it — it takes CBE learners to work through their studies and demonstrate competence. Having recently read two excellent reports on CBE I was struck by the almost universal use of the term ‘self-paced’ to describe the rate of learner progress in CBE instructional models.

I’m sorry but (IMHO) — use of the ‘self-paced’ term seems wrong for two reasons.

photo of different sizes of people all jogging down a track.

“Self-paced” works for some activities.

“Self-paced” Equates with Correspondence, “Learn-on-your-own” Studies

First, and most importantly, the term ‘self-paced’ is specifically used in the Code of Federal Regulations to describe (enable classification of a course as) a correspondence course (“Correspondence courses are typically self-paced,” Sec. 484(l); 34 CFR 600.2).  For many degree-seeking learners this is bad because correspondence courses and programs are ineligible for Title IV financial aid.  Yes, there is the caveat ‘typically’ but — as I watched one college take three months to debate and resolve this nuance with an accreditor — it is like waving a red flag at a bull and then putting it back in your pocket — it doesn’t un-ring the bell (apologies for the mixed metaphor).

Deb Bushway, a CBE consultant with Lumina Foundation,  noted these concerns in a recent paper where she explained:

“When these regulations were developed, describing something as a “self-paced course” was a proxy for “left to learn on his/her own,” because the technology and knowledge was not yet available to track and personalize the educational experience. In the intervening years, advances in technology, predictive analytics, cognitive science, and instructional design have a spawned the creation of the new generation of academic innovators. In these programs, personalized pacing might leverage recent advances to support student learning and progression at a level that has not been achieved by even most traditional programs. In short, a “self-paced course” in 2016 does not necessarily leave a student to “learn on his/her own.”

CBE Isn’t All that Self-Paced

My second kvetch with ‘self-paced’ is that it is operationally inaccurate.  For students enrolled in CBE courses and programs that are credit bearing and eligible for financial aid — CBE is NOT a ‘self-paced’ option or experience.

While almost every CBE model is designed to give the student significant latitude and agency over their pace — the control is not unilaterally at the discretion of the learner.  It is a negotiated flexibility, with milestones, deadlines and absolute limits, arbitrated between course designers, faculty, learners — and regulators — to ensure there is ‘satisfactory academic progress’ to maintain financial aid eligibility.

In short, the variability of pace in CBE is not without boundaries.  And the limits are not, ultimately, set by the learners themselves.  Even without the regulatory requirement to ensure the student’s pace is sufficiently productive — experience tells us, that when learners are left to their own initiative to engage with and progress through a course of study, most tend to lapse, languish and leave.  Most recently the completion rates of MOOCs have provided a stark demonstration of this syndrome.

Let’s Get it Right

It is important that we get this concept — and term — right.

Recent findings (Editor’s Note: this was written prior to last week’s WASC criticism by the OIG) by the U.S. Department of Education’s Office of the Inspector General (OIG) have had, and could have a greater, chilling effect on CBE development.  With a report already issued criticizing the oversight of CBE programs by the Higher Learning Commission – and a review of Western Governors University nearing conclusion – we are learning how the OIG’s focus on terms and nuance (in WGU’s case “regular and substantive interaction’) could engender large, negative consequences for the well-intentioned efforts of the CBE movement.

Emphasize the Positive

Flexible pace is a big selling point of CBE.  Take more time where you need it, move ahead faster where you’re already skilled.  Every CBE program has had to confront and devise its own plan wherein learners can adjust and optimize their time spend learning and progressing balanced against other commitments and emergencies.  The six month term model provides sufficient ‘slack’ time that students can accommodate breaks, vacations, work, life and still find time to stay on — or exceed — the progress students made in a traditional 15-week learning window.

As I’ve pointed out, allowing learners to devise and manage their learning schedules alone is contraindicated.

A track coach is leans down next to a young runner who, apparently just completed a race. The coach has his arm around the runner and appears to be consoling him.

CBE students often receive coaching from their “Academic Friend Forever”

Many CBE programs address this challenge with a ‘success coach.’   This tactic, what I like to think of as a learner’s “Academic Friend Forever” — or AFF, establishes a person-to-person relationship that ensures on-going engagement and adjustments for on-track progress for the entire program. The coach maintains regular contact with the learner.  Usually by phone weekly at the beginning of a program, generally less (bi-weekly) as the student progresses and establishes and demonstrates strong time management skills.  From the start, and throughout the duration of study, the coach and learner negotiate the pace and progress that is anticipated, will be attempted and has been achieved.

Also emergent in exemplar CBE models is the use of instructional technologies, including the adaptation of customer relationship management (CRM) software to develop, maintain and grow a progressive, persistent student profile that can be accessed and utilized by an entire team of instructional and learning support professionals.

These tactics and tools enable increasingly informed, accurate and effective management of pace and progress by individual learners.  The result is a learning model where the pace is negotiated and customized to the individual’s personal abilities and circumstances within a reasonable (and regulatory) set of boundaries.

It’s Time to Stop Using “Self-Paced”

To recap:  The primary reason to stop using the term ‘self-paced’ is to avoid unintended confusion and/or classification of a program as ‘correspondence’ when it is intended to be for-credit and financial aid eligible.  AND — the pace of progress through CBE instruction is not determined unilaterally by her/himself — the pace is a bounded, negotiated, customized pace for each individual learner.

What makes this benefit unique is that, on any given day, for any given learner, the pace and progress will always be different.  And it is this individuality that provides a better term (or set of terms) to use.

THEREFORE and FORTHWITH EVERMORE: In describing the pace of learner advancement through competence-based instruction we now have a rich set of more accurate and descriptive terms that can be used.  These include: personalized-, individualized-, customized-, and flexible-pace and other variants to fuel your creativity.  I myself am beginning to favor the term ‘multi-paced.’  I’ll let you know how that works out.  But please, can we be resolved to eradicate the self-paced moniker from our minds — and our for-credit, financial aid eligible CBE courses, programs and models?Myk wearing glasses and smiling over his white beard and snazzy black shirt.

Myk Garn
Assistant Vice Chancellor for New Learning Models
Board of Regents of the University System of Georgia

 

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Running photo credit: Morgue File
Coach photo credit: Morgue File

Call to Action: Comment on State Authorization for Distance Education Regulation

I encourage you and/or your institution to submit comments on the state authorization regulation proposed recently (press releaseproposed regulations) by the U.S. Department of Education. In a recent post, I gave you a “first look” at the language, included some analysis about what is new, and commented on some implications.

In this post, I will provide you with background and opinions on four of the elements of the proposed regulation and suggest some other topics on which you may wish to comment. I also provide you with some possible language that you might use in your comments. Finally, I give you information on how to comment.

The comment period ends August 24.

Please don’t use the excuse that you are a State Authorization Reciprocity Agreement (SARA) member to not pay attention. Much of what is proposed has an impact on everyone…and some of it directly affects SARA members.

If you plan to have your institution comment, get motivated. Understandably, it often takes some time for draft comments to make their way through institutional review and approval processes before they can be submitted. Alternatively, you can comment on your own.

Picture of a hand with a watch and a pen. The words "The Time to Comment is Now" appears on a letter presumably being written by the person in the photo.1) Initial Overview

Let me complement the Department for trimming the proposed language from what was presented to the Negotiated Rulemaking panel (for which I was a negotiator) in 2014. The language is much clearer and less redundant. I still have some questions, but fewer than I had two years ago.  I also laud the Department for focusing on the key issues.

One of my biggest worries is the answer to what protections are included in “consumer protection” as part of the reciprocity definition. Interpreted broadly, it could cripple SARA, but I sincerely doubt that is the Department’s intent. Second on my list is the attempt to use out-of-state institutions to get states to develop their complaint processes. I agree with goal, but their proposed process will not allow us to reach that goal very soon. See more on both points in the discussion below.

For institutions, if you have been paying attention to state authorization rules, you should (mostly) be okay. If you have not been paying attention (oh my, why is that, the state regulations have been there all along), you better get going.

For students, these regulations will provide more protection. Students will also receive more information about the programs they seek to enter.

Bottom line: Keep the focus on the student.

2) Institutional Compliance

Background and Department’s Proposed Language

The proposed regulation requires institutions to demonstrate that they have the proper authorizations in any state in which they enroll a student who receives Title IV funds. The language:

“If an institution described under paragraph (a)(1) of this section offers postsecondary education through distance education or correspondence courses to students in a State in which the institution is not physically located or in which the institution is otherwise subject to that State’s jurisdiction as determined by that State, except as provided in paragraph (c)(1)(ii) of this section, the institution must meet any State requirements for it to be legally offering postsecondary distance education or correspondence courses in that State. The institution must, upon request, document to the Secretary the State’s approval.”

Opinions

Support the Department’s return to the 2010 intent. First, this issue was the major sticking point of the Negotiated Rulemaking process held two years ago. In the original regulation, issued in 2010, the Department asked institutions to follow existing state laws, if any. In the 2014 Negotiated Rulemaking, the Department sought to make every state conduct an “active review” of every institution. The great majority of negotiators (10 or 11 out of 16) did not support that idea. I am pleased to see that this proposal returns the Department to the original regulatory framework that colleges must follow any existing state laws. The uncertainty that the “active review” implementation would have caused would have harmed students. Keep the focus on the student.

Second, I know that many in the higher education community wish this federal regulation would go away. I don’t agree. For the amount of federal funding that institutions receive, asking colleges to follow state laws is a reasonable expectation. In talk about regulations, the impact of protecting students is sometimes lost. Keep the focus on the student.

There definitely will be groups that will try to influence the Department to try to force each state to conduct an “active review.” Their focus is on “for-profit” institutions, but “for-profit” institutions already have additional authorization requirements in many states and have (usually) already complied with them.  The “active review” would have been an unfunded mandate for an activity that those states did not see a need to enact by now. The resulting chaos for non-SARA states and institutions would have left students uncertain whether or not they were enrolled in or considering an approved institution. Keep the focus on the student.

Corinthian Colleges is rightfully used as the poster child for an unsavory for-profit that wasted federal funds. Those seeking more regulation called Corinthian an “online institution.”Actually, Corinthian Colleges was a collection of 60 colleges, only five of which enrolled a significant number of students (more than 10% of total enrollment) solely at a distance. Lax oversight by Corinthian’s accrediting agency has been covered extensively in the press. But Corinthian is based in California and that state’s oversight is also wanting and has been totally absent, at times. California’s oversight problem will only be fixed by long-overdue direct Departmental negotiations with the state. Indirect regulations depending on out-of-state institutions lobbying the California legislature to change their laws will not improve student protection. Keep the focus on the student.

 Possible Language for Commenting

We support the Department of Education’s return to the original 2010 regulatory intent to assure that institutions offering distance and correspondence education in other states are following the existing laws of each state in which it enrolls students.

3) Reciprocity

Background and Department’s Proposed Language

The proposed regulations recognize reciprocity among states as a valid route to meeting Department of Education state authorization requirements. Note that the Department can only endorse reciprocity as a concept and cannot endorse any specific model, such as the State Authorization Reciprocity Agreement (SARA). The language:

“If an institution described under paragraph (a)(1) of this section offers postsecondary education through distance education or correspondence courses in a State that participates in a State authorization reciprocity agreement, and the institution is covered by such agreement, the institution is considered to meet State requirements for it to be legally offering postsecondary distance education or correspondence courses in that State, subject to any limitations in that agreement. The institution must, upon request, document its coverage under such an agreement to the Secretary.”

In the Department’s recommendations, they propose a new definition:

“State authorization reciprocity agreement. An agreement between two or more States that authorizes an institution located and legally authorized in a State covered by the agreement to provide postsecondary education through distance education or correspondence courses to students in other States covered by the agreement and does not prohibit a participating State from enforcing its own consumer protection laws.”

A map of the United States with SARA states highlighted. California, Connecticut, Florida Kentucky, Massachusetts, New Jersey, New York, Pennsylvania Utah, and Wisconsin are not SARA members.

As of August 1, 2016, 40 states and the District of Columbia participate in SARA. Watch for 3-6 more states in the coming months.

Opinions

Support the Department’s Proposal. Department leaders have continually issued strong support for the idea of state-to-state reciprocity agreements serving as a means to fulfilling this requirement. The Department should be thanked for re-affirming that support in the proposed language.

Request Guidance on the “Consumer Protection” Term. We believe that the intent of the term “consumer protection” refers to general fraud, misrepresentation, and abuse laws that could be applied to any business or activity in the state – including colleges and universities. SARA’s provisions focus on the requirements for institutions to offer postsecondary education in a state and not the rules for operating as a business in the state.

If a broader definition is used, then a state could define any institutional requirement as consumer protection. Under that scenario, a state could enforce any of its previous rules. That would end reciprocity. Given the Department’s support for reciprocity, we don’t believe that is their intent.

SARA opponents have attempted to confuse this issue by falsely claiming that SARA keeps states from pursuing fraud, misrepresentation, or abuse claims by those residing in their state. To the contrary, SARA’s Policies and Standards document states:

“…SARA member states continue to have authority to enforce all their general-purpose laws against non-domestic institutions (including SARA participating institutions) providing distance education in the state, including, but not limited to, those laws related to consumer protection and fraudulent activities.”

With “general-purpose laws” being defined in the SARA Policies and Standards document as:

“A ‘general-purpose law’ is one that applies to all entities doing business in the state, not just institutions of higher education.”

Unfortunately, the untruth about SARA’s restrictions has been repeated often enough that the Department decided to add this language.

Possible Language for Commenting

We applaud the Department of Education’s on-going support of reciprocity as a means for institutions to obtain state authorization for distance and correspondence programs offered to students in other states. The success of reciprocity is witnessed by forty states and the District of Columbia joining the State Authorization Reciprocity Agreement in just two-and-a-half year. Additional states are slated to join in the next six months.

The proposed definition of “state authorization reciprocity agreement” bans any such agreement from prohibiting “a participating State from enforcing its own consumer protection laws.” A clarification of “consumer protection” is needed to help those enforcing a reciprocity agreement and the agreement’s member states understand the Department’s intent. Rather than clarifying the intent in regulation, we support future guidance in comments when issuing the final regulation and a “Dear Colleague” letter. The guidance should affirm “consumer protection” laws as being limited to general purpose fraud, misrepresentation, and abuse laws that apply to all entities doing business in a state, not just institutions of higher education.

4) Student Notifications and Disclosures

Background and Department’s Proposed Language

The proposed regulations include several new notification and disclosure requirements for distance education students. Both enrolled and prospective students are to be notified. Some requirements are for “public disclosures” (such as by website and catalog) and some are “individualized disclosures” (directly to the student via email or U.S. Mail).

The new requirements with possibly the most impact will be those for programs that lead to licensure or certification in a profession. Of course, the licensure and certification requirements vary greatly across professions and states. This issue was not addressed in the original regulatory language from 2010. During the Negotiated Rulemaking, Marshall Hill (NC-SARA Executive Director and fellow negotiator) and I supported some form of notification for such programs. We did oppose when they tried to expand the requirement to ALL programs, both those at a distance and face-to-face. We felt that such an expansion was outside the scope of the Rulemaking.

The “public disclosures”:

  • State authorization. List the states in which the institution is authorized (or whatever term the state uses) to provide the distance program. Also, whether that authorization was provided by the state or a reciprocity agreement.
  • The complaint process and contact information for the institution’s state, the reciprocity agreement (if the institution participates in such an agreement), and the student’s state.
  • Adverse Actions. Institutions are to disclose any “adverse actions by a state entity or accrediting agency…”related to postsecondary education programs offered solely through distance education or correspondence courses at the institution for the five calendar years prior to the year in which the disclosure is made.”
  • Refund Policies. Disclose refund policies with which the institution is required to comply.
  • Professional Licensure Approvals. For programs offered at a distance that lead to professional licensure or certification, notify students of:
    • The state’s educational prerequisites for that occupation.
    • If the institution determined whether or not its program meets a state’s prerequisites, disclose that fact to potential students in that state.
    • If the institution has not determined if its program meets a state’s prerequisites, disclose that fact. If you enroll any students in that state, you will be subject to the individualized disclosure below.

The “individualized disclosures”:

  • Institution Meets Licensure and Certification Requirements. To prospective students in a state, notify the student whether the program meets the educational prerequisites of that state.
  • Adverse actions. Notify students of any new state or accrediting adverse actions within 30 days. Notify students if the program ceases to meet licensure or certification prerequisites within seven days of that determination.
  • Student acknowledgement. If an institution enrolls a student in a program in a state in which it does not meet certification prerequisites, the student must acknowledge having received that disclosure.

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

Complaints. The complaint disclosure is a bit puzzling since institutions have been required to disclose the complaint process in each state since July 2011. This new requirement seems to go a bit further in that the institution is asked to document that the complaint process will actually function in the student’s state. It’s akin to an insurance company requiring the policy holder to make sure that the police departments in neighboring towns will actually cite speeding drivers. Some states might not be able to take complaints from students from “exempted” institutions. I’m 100% in favor of 100% complaint process availability for all students.

Since 2010, the Department has been trying to get states to have complaint processes for all students within the same state as the institution. They used this same regulatory approach and it has not worked well. In-state institutions have had a hard time getting legislatures to create complaint processes for in-state institutions in some states. It will be nearly impossible for out-of-state institutions to be effective in lobbying legislators to improve their complaint process.

An unfortunate outcome may be that some legislators will see this as a “protectionist” option. Through inaction they can encourage out-of-state institutions to stop serving students in their state. I do not think that was the Department’s intent.

Getting complaint processes implemented in states that do not have them will take a significant amount of time and effort, none of which is reflected in the estimate of burden for implementing this recommendation. As a result, the uncertainty of whether an institution can offer aid to distance students in those states will cause considerable confusion for students.

In its brief, Cooley, LLP encourages “schools to press the Department to identify which states, in the agency’s view, currently do not have an adequate student complaint system to satisfy the new distance education requirements. Elementary principles of due process would require that institutions have some notice and opportunity to cure any defects with regard to state law (over which they may have no control) prior to losing access to Title IV funds.

Schools should consider asking for clarification on whether home state complaint procedures, if disclosed to students, could afford sufficient consumer protections to satisfy the Department. If a state chooses not to assert jurisdiction over an online program, and therefore no authorization is required under the federal rule, arguably that decision should simply be respected consistent with the principles of federalism.”

The Department will probably reject this last suggestion. I wonder if they would at least consider it as a stop-gap until the distant state creates an adequate complaint process.

Adverse Actions. Accrediting agencies use this concept, but the same term for an action may vary greatly across agencies. For example, something that is a request for more information from one agency may actually be evidence of a serious offense for another. Also, clarification is needed for what types of actions are taken at the state level that should be reported.

Professional Licensure Approvals. It is my view that institutions need to be more proactive in determining if its program meets a state’s educational prerequisites if it is going to enroll students at a distance in that state. I’ve often heard that “it is the student’s responsibility” and that is a tragically selfish point-of-view that does not put the student first. The institution can’t argue both that: a) it is hard for experienced institutional personnel to determine if the institution meets the prerequisites in each state and b) that a student who has yet to take his/her first class in the field has any hope of understanding the academic and legal nuances involved. That being said, it is much, much harder to understand the requirements and obtain approvals from the many boards than the Department reflects in its estimation of burden section of the proposed regulation. In fact, the Department’s estimates are disastrously low. Compounding the problem, as we saw in 2011 with the federal state authorization regulation was to go into effect, there will be a “land rush” on professional board offices. Those offices will be ill-equipped to handle the work and inquiries since these activities were not in their work plan. Since this is a new requirement, the Department should give several years before enforcing it.

Possible Language for Commenting

We agree with the Department’s goal of assuring that every student has access to a robust complaint process. However, the Department’s proposed regulation’s reliance on out-of-state institutions to lobby for changes in other states’ complaint practices will be slow to produce results. Out-of-state institutions will have little influence over the legislatures of states lacking an adequate complaint process. We encourage the Department to work with WCET and  NASASPS (the state regulator group) to develop a strategy for more quickly assuring that students will have access to robust complaint processes. Meanwhile, we suggest that the Department identify the states that are out of compliance, use a long lead time before enforcing this requirement, and consider using the institution’s home state complaint process.

The Department should supply more guidance on how “adverse actions” will be implemented. How should institutions address when similar terms have different meanings across accrediting agencies? Which state actions should be included as “adverse actions”?

For the professional licensure and certification notifications, the Department’s estimate of burden woefully underestimates the amount of time institutions will spend in fulfilling this requirement. The process includes initial research, application processes, coordination within the program and institution, and numerous interactions with board staff.  Additionally, professional boards in the states will be overwhelmed with requests. The boards will not be staffed to handle the volume of inquiries and turn-around will be even slower. Therefore, we suggest that the Department not enforce this provision for at least three years after enacting the regulation.

US-Capital-by-Stephen-Melkisethian5) Other Issues About Which You May Wish to Comment

In the previous sections, I have highlighted the areas of main concern for distance education providers. Depending on the interests and activities of your institution, you may also wish to comment on the following items:

  • Aid Consequences. Thank you to our friends from Cooley, LLP law firm for raising this question: “To head off future issues, we encourage schools to seek clarification from ED as to whether institutional eligibility or programmatic eligibility is at risk for failure to obtain authorization for distance programs in any particular state. In other words, if one fails to demonstrate state authorization in a particular state, does that mean the eligibility of the institution is at issue, or just the eligibility of particular programs in a state?”
  • Hybrid courses/programs. The regulations seem to omit any federal oversight of hybrid programs while the states are still very interested in these activities. If they had followed my advice and focused on geography and not mode of instruction, they would have solved many of these problems. By focusing on “distance education” as the problem to solve, they are leaving some students unprotected. Go figure. You may wish to ask for clarification on how these regulations relate to students in hybrid programs?
  • Branch campuses or locations in foreign countries. If you have an independent branch campus or location where a student can finish 50% or more of a program in a foreign country, there are new state authorization requirements. I do not believe it covers agreements with foreign institutions, but you may wish to ask for clarification. Since this is a new requirement, you may wish to ask for additional time before this is enforced. Some states might not have a process to act on this requirement.
  • Students from states where the institution does not meet licensure/certification requirements. It is good to see that the Department understands that there are times when it makes sense for a student residing in a state for which the program does not lead to licensure might still wish to enroll. For example, a military spouse might intend to return to the institution’s home state to practice after his wife’s tour of duty ends. During the Negotiated Rulemaking process, some negotiators proposed elaborate processes for this notification. One wanted each prospective student to write an essay indicating her/his understanding of the consequences. This would be a nightmare for the student, the program, and any English majors who happen by. You may wish to ask for clarification on what type of acknowledgements would be acceptable and request that such acknowledgements not be too complex for the student.

6) How to Comment

Join the fun. Reply! VOLUME COUNTS.

Who Should Reply?

Institutions, programs, or individuals may reply. If you serve students via distance education in other states, you should consider replying. For an institutional or programmatic reply, you need to navigate the proper government relations channels at your institution. This may be difficult given the August 24 deadline.

If you reply as an individual, you can’t use your institution or organization letterhead. You can supply your name, title, and employer. It might be good to reiterate that you are not responding in your official capacity.

How Do I Reply?

Directions on how to reply appear in the “Addresses” section of the Supplemental NPRM (NOTE: link updated 08/22/16). You may: “Submit your comments through the Federal eRulemaking Portal or via postal mail, commercial delivery, or hand delivery. We will not accept comments submitted by fax or by email or those submitted after the comment period. To ensure that we do not receive duplicate copies, please submit your comments only once. In addition, please include the Docket ID at the top of your comments. If you are submitting comments electronically, we strongly encourage you to submit any comments or attachments in Microsoft Word format.”

If you plan to use the Portal, give yourself some time to figure it out or get help from the person who usually submits comments for your institution. Read the specific instructions on pages 2 and 3 of the proposed regulation.

What Should I Say?

Personalize it as form letters get less attention. Briefly tell your story. Who are you? What impact would these regulations have on students? What impact would these regulations have on your program? Focus on what would have the greatest impact on you and your students. Say why the proposed would regulations would help or hurt you, your institution, and (especially) your students. Discard the rest.

Be respectful. We can be better than the presidential nominees.

Make positive or helpful suggestions. Personally, I hate the responses which object to everything without supplying, at least some, helpful alternatives. This helps to address the sense that we are merely objecting to any type of oversight or anything that inconveniences us. I’m for regulations that serve a purpose and for which the cure is not worse than the disease.

Ask questions about clarifications that are needed.

7) WCET Will Submit Comments

WCET in partnership with the WCET State Authorization Network will be submitting comments. We are also talking to other organizations about partner in commenting or to endorse our comments. If you know of any such organizations, have them contact me.

Sorry this got so long, but there is much to say and much context to understand.

Good luck in submitting your comments! Thank you for your help!

RussRuss Poulin holding a baseball bat.

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

Native Alaskans Use Digital Storytelling to Explore and Share

A trim hiker in black shorts and a blue sleeveless shirt stands atop a mountain, her arms raised in victory. This image literally headlines Eva Gregg’s digital eWolf portfolio. That’s her in the picture.

Eva raises her hands in triumph at the top of a peak with no trees. Beyond her is the vast vista of Alaska.

This image tops Eva Gregg’s ePortfolio, where she describes challenges and successes in her life, from the personal and cultural to the academic. (Photo courtesy of Eva Gregg)

“I am a hiker!” she says emphatically to a small group of Alaska Native elders and community workers. “This is important to me. At one time, I weighed 252 pounds.” Later in her portfolio, she writes, “I never thought in all my life that I would be conquering mountains….”

In fact, Wolverine Peak, a 10-mile hike that takes Eva eight hours, is her favorite endeavor. But highly popular Flat Top eluded her for a long time. The last steep section to the summit terrified her, she said. Yet, after watching two disabled hikers and a toddler skitter up, she managed it. “There are no excuses,” she says, laughing heartily.

Kotzebue-born and raised, now age 49, Eva is the mother of four and a UAA college student. Flashing pages of her digital portfolio on a large screen, she demonstrated the different ways she has used this new tool to tell her own story, including her battle against obesity.

Identifying the Elements of Digital Storytelling

Eva Greg standing in front of a sign on intentionally weathered wood that reads "Native Student Services". She is a Native Alaskan with black hair and a few white specs in it.

Eva Gregg stands before the University of Alaska Anchorage Native Student Services center where she presented her Native cultural identity ePortfolio to a group of elders and community workers. NSS is working with community members to make this digital storytelling tool culturally relevant. (Photo by Ted Kincaid/University of Alaska Anchorage)

Just moments before, Sheila Randazzo, transition advisor for Native Student Services, and Paul Wasko, coordinator for UAA’s ePortfolio initiatives, had teamed up to set the stage for what Eva’s audience was about to see. They hoped this gathering of wise and caring community members could hear the power in Eva’s digital storytelling. And they hoped this group might help shape and frame this new tool—a Native cultural identity ePortfolio—for UAA’s indigenous students to “understand and record their journey of becoming aware of who they are,” as Randazzo explained.

Specifically, the NSS team requested writing prompts from the community members to help students begin their ePortfolios and digitally document their identity journeys. As Wasko told them: “These are like chapters in a book. A blank page can be intimidating. But if this is my electronic book, I need a chapter on knowledge, on the physical, the emotional. Instead of financial, we might say ‘provider.’ Can you give these students prompts for what needs to go on those pages?”

“We need your wisdom,”  added diversity expert Tommy Woon. “This is a partnership with the community. We don’t want to see it contained here, just on campus. Everything is connected. We are your servants and you are our board of directors.”

Woon has been visiting and informally advising NSS as it works to develop the identity-relevant ePortfolio. He has worked a lifetime encouraging diversity at Stanford, Dartmouth and now Naropa University, a Buddhist-inspired institution in Boulder, CO.

Liberating Native Students Through Digital Age Tools

One of the disparities Woon said he is sensitive to is seeing minorities left behind in the wake of major technological change. As he told the elders and community workers gathered, “We have had the agricultural age, the industrial age, the technological age. Now we are in the digital age. Whenever new technology comes along, it can deepen the gap between the haves and the have-nots, leaving them further behind.”

Instead, he challenged, “Why not use it for liberation work? Young people doing digital work get more computer- and digital-literate. They can develop it and use it to get jobs.”

And they can use it to explore and understand their cultural identity. Woon’s own Korean/Japanese family experienced historical trauma dating back to World War II. “It is very personal to me,” he said. “The sting of discrimination is still public in Japan.”

He envisions Alaska villages with their own ePortfolios. “Their stories can be archived. They don’t have to rely on oral history. This can be their digital oral history. It can promote belonging, and point the way to resources when needed.”

From his days working at Stanford, Woon knows Helen Chen, director of that campus’s ePortfolio initiative and a premier researcher in the field. She wanted Woon’s take on how this tool could best be used by minority students. From all his work in diversity, Woon quickly imagined concentric circles: self, family, community, traditions, ceremony and the environment. “Have the students explore how they came to be through those things. Let them interview their elders, do their own research, and in those ways define themselves and document their journey,” he told Chen.

With his glasses on his head, Paul Wasko uses broad hand gestures to illustrate his point.

Paul Wasko heads up UAA’s ePortfolio initiative across the campus. (Photo by Ted Kincaid/University of Alaska Anchorage)

ePortfolios Capture a More Complete Story of the Person

Wasko worked in Minnesota when the state decided to scale the ePortfolio concept. Every resident could have one. The goal was a kind of K-20 education-to-career personal learning tool and map.

The goal: “If I am a student, how do I emerge from college into a job?” he said. “Or, if I am laid off, how do I track my way through getting more education so I can cycle successfully back into the work world.”

By Revealing Your Story, You Help Yourself and Help Others

Eva’s ePortfolio is a window into how a truly authentic voice can emerge in a digital environment, and how she is able to capture so much more than her grades or job history. Her writing expresses personal validation for her successes, and honest acknowledgement of her obstacles and challenges.

Her opening page, called ‘My Path,’ addresses pivotal moments in her life. That time in fifth grade when she finally stood up to four class bullies. Her first alcoholic blackout in seventh grade. And the moment, 30 years later, when she publicly admitted, ‘Hi, my name is Eva … and I need help.’  She’s been sober and clean since December 2009.

Decembers are big months for her, her story reveals. The very next one, in 2010, her best friend and the father of her daughter died. “I thought I would relapse…but I did not which surprised me.”

Sporting a broad smile, Eva is shown at a computer with her eportfolio on the screen.

Eva Gregg, at work on her ePortfolio. (Photo by Ted Kincaid/University of Alaska Anchorage)

She now plans different ePortfolios for different audiences: one for scholarship applications, one for job applications, one for family. Her mountain climbing story isn’t the only one that reveals her grit and determination.

After two years in college, she has plenty of papers and math tests under her belt. “I love math, don’t get me wrong. It really makes me think. But it’s time-consuming and hard.”

What does she do when she gets stuck on a problem? “I watch YouTube videos on algebra, for hours. I watch the videos and then I go back to the problem.” Only after exhausting all ideas and resources—from the videos to her class notes to the book’s explanation, does she resort to asking for help. She might post the problem on Facebook, and query her several math-savvy cousins: “I am stumped guys,” she writes. “Show me step one. “

What’s Next?

In December 2012, Eva wrote in ‘My Path,’ standing at her sink washing dinner dishes, she wondered how and why she’d managed to survive three decades of alcohol, drugs “and the trauma that goes hand in hand with that lifestyle.” She decided, then and there, that she would spend her life supporting any addict willing to work as hard as she has for her sobriety. She’s aiming for social work and human services degrees.

“I want to help people like me,” she said later. “They know they are stuck in something and can’t get out. If they ask me for help, I am willing to help them.” She has found her way to solid self-worth and to a career.

 

 

Thank you to Paul Wasko (ePortfolio Initiative Coordinator, Academic Innovations & eLearning, University of Alaska Anchoragepwasko@uaa.alaska.edu) for his help in arranging for this story.  Paul has been a long-time supporter of WCET

A version of it originally appeared in the University of Alaska Anchorage Green & Gold News. Thank you to Kathleen McCoy, Editorial Director, UAA Office of Advancement for her help in arranging for us to publish this story.

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

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.

Russ

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

 

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