On the OIG/WGU Finding, Part 1: When Interaction Is Not Interaction

Yesterday, the U.S. Department of Education’s Office of Inspector General (OIG) issued a report concluding:

“We concluded that Western Governors University did not comply with the institutional eligibility requirement that limits the percentage of regular students who may enroll in correspondence courses. Therefore, the Department should require the school to return the $712,670,616 in Title IV funds it received from July 1, 2014, through June 30, 2016, and any additional funds it received after June 30, 2016.”

The OIG report header reading: "Western Governors University Was Not Eligible to Participate in the Title IV Programs: Final Audit Report"

This recommendation is based upon the OIG’s interpretation “regular and substantive interaction.” The phrase appears in Chapter 34, §600.2 of the Department’s definitions of the term “distance education” as a means to delineate it from “correspondence education.” Institutions can grant Title IV aid for only a limited number of correspondence courses.

Western Governors University (WGU) created a webpage describing its position regarding how its leaders feel they complied with the regulations.

Blog Post Series

This is the first in a series of blog posts regarding the OIG’s actions. Today we focus on our history on this issue and on the notion of “interaction.” In a future post (or posts?), we are planning to talk about:

  • The notions of “regular” and “substantive,”
  • the specific application of “regular and substantive interaction” in the WGU case,
  • what that might mean to others offering competency-based education (CBE) and distance education, and
  • what you should do about it.

Improving Quality and Access Do Not Matter?

In our initial look at the report, Van Davis (Associate Vice President of Higher Education Research and Policy) and I took particular note of this comment on page 6 of the OIG’s report on WGU:

“We (OIG) did not assess whether the school’s model was improving educational quality or expanding access to higher education. We are not withdrawing our findings or the corresponding recommendations.”

While we will say more about the report in upcoming posts, we felt that saying that it does not matter whether an institution actually serves students well is an astonishing. This is a severely troubling statement.

Departmental Guidance on “Regular and Substantive Interaction”

The interpretation has been difficult. I have been following this issue since I first reviewed findings of an audit report on St. Mary-of-the-Woods College back in 2012. That post consistently remains one of our top viewed posts each year. Last I heard, the recommendations in this report have yet to be resolved. A final resolution for WGU might have a similar fate.

That report was issued five years ago. In the intervening time, the communications from the Department of Education in communicating its expectations on how institutions are supposed to comply have been few and far between. In August, 2016, WCET published a great post by Myk Garn (Assistant Vice Chancellor for New Learning Models with the Board of Regents of the University System of Georgia) on “Why We Need to Stop Using ‘Self-Paced’ in CBE Descriptions.” Because of the minimal guidance, the issues raised by Myk, and my worry that people were relying on the St. Mary-of-the-Woods College blog post as their guidance, Van Davis and I reviewed all the materials we could find. After reviewing “Dear Colleague” letters, the financial aid handbook, and audit reports, we penned the post “Interpreting what is Required for ‘Regular and Substantive Interaction’” in September, 2016 to assist institutional personnel seeking to comply with the regulation.

From the St. Mary-of-the-Woods report to our review last year and culminating with the OIG findings on WGU, OIG interpretations and how it applied those interpretations changed. Many of the essential points remain the same, but important new criteria have been added over time. Van and I were communicating yesterday on some of the criteria applied to WGU and wondered “where did that come from?” We will get into more specifics in a future post.

Bottom line: The Department of Education is usually very clear in stating the criteria and measures that will be used in assuring compliance with federal financial aid laws. This is not the case on this issue.

When is Interaction Not Interaction?

The idea of “regular and substantive interaction” is anchored in a noble goal that we all support. We do not want federal financial aid dollars going to fraudulent educational activities. There were fraudulent correspondence courses in the past in which the instruction was left mainly to the student’s own devices. As a result, severe limitations were placed on the number of correspondence courses that could be included in an institutions financial aid package.

The notion of “interaction” was used as the main line of demarcation between correspondence and distance education. The problem is that the notion of quality academic interaction is not really what is defined in the regulation. In the Department’s definition of “correspondence course”:

“Interaction between the instructor and student is limited, is not regular and substantive, and is primarily initiated by the student. Correspondence courses are typically self-paced.”

The OIG is looking for interaction that is:

  • Initiated by the faculty person.
  • On a schedule set by the faculty person.

That’s not interaction, that’s dissemination. Both Merriam-Webster and I have a richer view of “interaction” as an activity that is more give and take and not one-way:

From the Merriam-Webster Dictionary, the excerpt reads "Definition of interaction: mutual or reciprocal action or influence."

The problem with applying that definition to competency-based education is that:

  • Interaction with a student is far more frequent than in a traditional course. Ironically, CBE courses are being called correspondence courses (which have almost no interaction) simply because of who initiates much of the activity.
  • The student has more control over the schedule for interaction. CBE is popular with adults who need flexibility in their timing. In correspondence education, students were allowed to float on their own with long stretches of inactivity. That does not happen in good CBE instruction as there is frequent contact to make sure that the student is progressing toward his or her goals.

Bottom line:   In talking about the high ideals of interaction to the public, the OIG is playing off the Merriam-Webster notion of interaction that is probably resident in most of our minds. Meanwhile, in applying their definition in practice, they are expecting compliance with an historic model of faculty lecture, dissemination, and control. CBE is not someone lecturing for 54 minutes and asking “any questions” in the last minute. That’s not good interaction in any instructional setting, including face-to-face. Such poor interaction is simply not possible in CBE instruction.

What Might Happen?

The OIG is making a recommendation and this is not the final word. From Michael Goldstein (Cooley, LLP):

“The IG’s report and recommendations go to Federal Student Aid, which decides what, if any, action should be taken. (The “if any” is directly from the IG transmittal.) That involves a further, and often lengthy, review process. The ultimate decision authority is the Secretary.”

Lengthy? Remember that the St. Mary-of-the-Woods report was released in 2012.

Watch for more to come in upcoming posts.Photo of Russ Poulin


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

WOW Award: Oregon State University’s Virtual Microscope for Distance Students

This year I had the exciting opportunity to coordinate our WCET Awards initiative. The most valuable aspect of this initiative was the chance to learn about the meaningful, student-focused work being done by various institutions and organizations in higher education. The WCET Outstanding Work (WOW) Awards honor member institutions and organizations that develop technology-based solutions to challenging educational needs. 2017WOW_Logo_0

I am pleased to announce the winners of the 2017 WOW awards: University of Central Florida, Blackboard Inc., Oregon State University Ecampus, and Healthcare Learning Innovations, a division of American Sentinel University.

Over the next several weeks, each of these institutions will be featured here on WCET Frontiers.

Today, we welcome Oregon State University Ecampus to discuss their award winning 3D Virtual Microscope. Congratulations to OSU Ecampus and thank you for your work to increase student success!

Enjoy the read and enjoy the day,

~Lindsey Downs, WCET

The Problem: Biology Students Needing Access to Microscopes

It was a fundamental question in search of a much-needed answer: How can distance students taking introductory biology courses online truly learn to operate a microscope without being in a physical laboratory?

The simple answer was that they couldn’t.

Students could buy a compound microscope to use at their homes, but with costs ranging from $50 for the cheapest ones on the market to well over $1,000 for the advanced variety, it was an untenable solution.

They could enroll in a campus-based course at their local college and use its labs. Commuting to and taking a class on campus, however, would further drain adult learners of their most valuable and fleeting resource: time.

The ultimate cost was that the lack of a sufficient, interactive online lab experience delayed and, in some cases, prevented many students from completing their degree requirements.

Those days, thankfully, are over.

The Solution: Create a Virtual Microscope

Oregon State University now offers a series of three biology courses online that effectively puts a microscope in the hands of every distance learner. Believed to be the first virtual microscope of its kind, this academic breakthrough is the result of a partnership between OSU’s Department of Integrative Biology, the Department of Botany and Plant Pathology, and Oregon State Ecampus, the university’s online education division.

The groundbreaking lab series recently won a WCET Outstanding Work (WOW) award, given to institutions that “implement exceptionally creative, technology-based solutions to contemporary challenges in higher education.”

It was a significant challenge. But trying to do something that’s never been done before is Oregon State’s comfort zone.

Easier Said than Done: Here’s How We Did It

Here’s the Reader’s Digest version of what it took for Oregon State to create the virtual microscope experience and, thus, eliminate a significant barrier to degree completion:

  • Six months of research and development
  • One year producing a 3-D microscope animation project
  • The collaboration of 30-plus OSU faculty, department heads, Ecampus multimedia developers, instructional designers and other staff

Dr. Bouwma, instructor with OSU EcampusDr. Andrew Bouwma and Dr. Genevieve Weber are the faculty members who piloted the development of the lab series. The end goal was not just to increase access to education but also to make that educational experience rigorous and engaging. The comprehensive development process was necessary to ensure the labs meet the same learning outcomes as OSU’s on-campus labs.

“I teach on-campus and online biology courses, and I wanted to find a way to give my online students the same, meaningful experience my on-campus students receive,” Bouwma said. “I started using the virtual microscope in my online classes immediately, and it’s been an effective tool in my teaching since it allows me to give my students more realistic assignments in cell biology, which I believe improves student engagement.”

The first step in building the virtual microscope was to design a way to replicate the in-person experience in an online, interactive environment. That massive undertaking was tasked to the OSU Ecampus multimedia development team, which pushed the limits of what’s possible in online education.

“I took the exact microscope that the students on campus use, and I measured it down to the millimeter so that I could model the virtual one precisely,” said Ecampus multimedia developer Nick Harper. “Then, using 3-D modeling software, I was able to manipulate basic shapes like cubes and cylinders to build an accurate digital model of a real microscope.”

Then came a year’s worth of animation work, using game development software that would enable students to manipulate all of the microscope’s controls – adjusting the brightness, increasing the zoom, focusing the viewer and so on. PHoto of the 3d microscopeThe Ecampus staff then mounted a camera on a real microscope and took photos of slides that were central to Bouwma’s instruction and programmed those images to create the virtual simulation.

“Ultimately, we were able to create a solution for students to maneuver a microscope’s settings and adjust the images the same way they would in a face-to-face environment in a lab,” multimedia developer Mike Miller said.

It Worked – with Minor Setbacks- and Has Been Expanded

It was a safe bet that the virtual microscope and corresponding online lab courses would be in demand among distance learners, but it has exceeded even Oregon State’s high expectations. Since the series was launched in 2015, OSU has had to add sections for each course in the online series because each one enrolls incredibly quickly.

The virtual experience has not been devoid of hiccups, of course. There have been some challenges with tech support along the way, but luckily the instructors are so familiar with the material and software that they answer questions quickly. Members of the Ecampus multimedia team also have been able to lend a hand when needed.

Oregon State has also added more slides, fine-tuned the virtual microscope’s features as needed. It’s also being used in other Ecampus classes, and it’s been added to the university’s open educational resources (OER) library, giving anyone in the world access to this innovative and, for many, essential tool.OSU 3d microscope 2

Success = Need + Collaboration

“When I describe this project to others, I tell them that this is the kind of collaboration that all others should aspire to,” said Shannon Riggs, the Ecampus director of course development and training.

“Everything was created based on student need, and that really galvanized all the people who worked on the project. It helped us approach the project with enthusiasm and passion – to boost student success and break down barriers to degree completion.”




Tyler Hansen
Marketing Communications Manager
Oregon State University | Extended Campus




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NC-SARA Institutions Report Enrollments

This week we are excited to work with NC-SARA to release two NC-SARA documents, the 2017 enrollment report and a paper comparing NC-SARA enrollments to IPEDS data from 2015.

Today on Frontiers we welcome Marshall Hill, Executive Director of NC-SARA, to provide an introduction to those documents. Thank you Marshall!

Enjoy the day and enjoy the read,

~Lindsey Downs, WCET

We are pleased today to release two documents relating to SARA: NC-SARA 2017 ENROLLMENT REPORT and a short paper that compares those reported enrollments to 2015 IPEDS distance education data — NC-SARA Reported Enrollment Mirrors National Distance Education Data with Some Notable Exceptions.

Both reports were prepared for NC-SARA by Terri Taylor Straut, Senior Research Analyst at WCET (the WICHE Cooperative for Educational Technologies).
Chart: 2017 reported enrollment. SARA Total (970,548 or 82.9%) and Non SARA total (200,177 or 17.1%)

The two documents, based on fall 2016 distance education enrollments reported to NC-SARA in the spring of 2017, summarize and analyze the reported enrollments of 1,477 SARA institutions.

Those institutions reported combined out-of-state enrollments of 1,170,725 students.

The majority (82.9%) of reported enrollments were in SARA states; 17.1% were in the three states that were not SARA members at the time of reporting (CA, FL and MA).

The institutional response rate for the enrollment survey was 98.9%; non-responding institutions have been contacted and have committed to report in the future.

Reported Enrollment in SARA States Reported Enrollment in Non-SARA States Total Reported Enrollment
2017 Reported Enrollments 970,548 200,177 1,170,725
Enrollment % 82.9% 17.1% 100%

SARA institutions each spring report their enrollment data to NC-SARA. These analyses cover the second annual reporting period. An Excel file of the reported data is available on the NC-SARA website.

As of today, 48 states, the District of Columbia and the U.S. Virgin Islands are members of SARA; in addition, Massachusetts has passed SARA-enabling legislation. More than 1,600 institutions participate in SARA.

Marshall Hill headshot


Marshall A. Hill
Executive Director




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Developing Effective Courses Using Adaptive Learning Begins with Proper Alignment

Similar to the birth of eLearning in the 1990s, the rush to implement adaptive learning has led to the development of poorly designed courses that are not properly aligned and fail to effectively implement the principles of multimedia learning. As a result, many institutions often proclaim their use of adaptive learning as a failure. Much of their disappointment with the initial results can be directly linked to the design of the course itself. One of the wonderfully unique strengths of using adaptive learning to deliver courses at the university level is the ability of the tool to illuminate gaps in the course design.

Oftentimes, universities make a swift decision to incorporate adaptive learning into a course, program, or department (and sometimes across departments when prompted by grants and other financial incentives) as one way to address their student success strategic initiatives. While adaptive learning is an excellent tool for improving student success across a university campus and its feeder system, little attention is usually given to the role of the faculty when redesigning courses for use in such a platform. Additionally, there is a gross underestimate of the time required to design and develop courses that are both aligned and adhere to the principles of multimedia learning. In an effort to most effectively take advantage of the power that lies in the use of a strong adaptive learning platform, faculty should be involved in the process from day one and the use of instructional designers should be considered a valuable use of resources.

Regardless of the delivery modality, poorly designed courses impact student success. It is past time we pay more attention to this critical issue as we now have tools that can provide support to students on a one to one basis. Attention to the development of a properly aligned course is imperative for student success. More often than not, however, most faculty completely ignore or lack knowledge of what proper alignment is, how to use it, and why it is important.

What is Proper Alignment?

Proper alignment means there is a direct connection, or correlation, between the course goals, the objectives, the assessments, and lessons. Proper alignment ensures that students learn what you intend for them to learn and are able to perform the tasks you expect them to be able to perform. One of the most effective ways to ensure proper alignment of a course is through the use of the backward design model. In this model, faculty begin with the end in mind and design the actual lesson last.

Headline reads

Beginning with the End in Mind: Course Goals

Faculty should ask themselves, “What do students need to know and be able to do by the end of this course?” Whatever it is that students should know and be able to do at the end of the course is the stick by which all other decisions about the course and its design should be measured. If an objective, assessment, or lesson does not contribute to that ultimate goal(s) of the course, it should not be included.Picture of a target with a dart firmly implanted in the bulls eye.

Faculty and other course developers should have a very narrow focus for each course they develop and always ask if each assessment and each lesson will help their students achieve the goal(s) for their course. Additionally, faculty should know that less is usually more in education. There should be no more than one, maybe two, overall goals for any particular course. Much thought should be given to exactly what the goal of each course is or should be.

When deciding to move a course into an adapted learning platform, it is crucial that the course has a clearly defined goal and that you are able to define what success means, especially if your university is working to meet student success initiatives. Defining success helps the adapted platform partner better meet your needs by providing yo u the most important data and identifying possible gaps in the course and curriculum.

Properly Aligned Learning Objectives

Anytime you have a large goal, you should have smaller goals that help you reach that larger goal. I like to explain to the students in my teacher education courses that a course goal and its objectives are like a ladder. The course goal sits at the top of the ladder and each rung on the ladder is an objective that students need to master in order to reach that course goal.

Another critical component of effective learning objectives is that they must be SMART (Specific, Measurable, Achievable, Relevant, and Time sensitive). This can be quite challenging for faculty to grasp. Each learning objective set must meet the SMART criteria to increase the likelihood of student success in any course.

When designing a course for delivery using an adaptive learning platform, you must map out the objectives and determine if these objectives must be learned in a particular order such as is typically the case with math courses as they follow a more linear path – you must be able to add and subtract before you can multiply and divide. Here, you are beginning to tap into the power of the adapted platform to highly personalize the course to each student’s needs based upon their incoming knowledge.

Properly Aligned Assessments

Hopefully by now, you have clearly identified your course goal and the learning objectives that will be needed to help students reach that goal. Now you are ready to think about how you will know if students reach the goal and how you will measure their progress toward meeting that goal along the way. My professional opinion is that effectively assessing students continuously is the backbone to learning.Cartoon of a

The days of giving a midterm and final should be over in higher education although I am clearly aware that it is not. This is clearly a training issue. Unless you have been trained as an educator, you may not have ever been taught how to teach. Unfortunately, just because you are an expert in your field does not mean you can do an effective job of teaching others. This is where the university must take a stand and begin requiring that faculty receive professional development and training around pedagogy/andragogy.

To determine how much students are learning throughout the course, the use of formative assessments are key. Here, you are assessing for learning. In an adapted course, these assessments allow you to provide detailed feedback and adjust the lesson for students on an individual and dynamic basis. Effective feedback is critical to increasing learning and it is essential that the feedback is timely. In an adapted course, feedback is immediate regardless of the time of day or night. No teacher can or ever will be capable of doing this without the assistance of a digital tool, such as an adaptive platform.

In my experience, getting faculty to understand the importance of and commitment to the development of effective assessments is the most challenging part of designing a course to be delivered using adaptive learning. While not new, variablized questions – assessment questions with multiple correct and incorrect answers – is an excellent assessment type to maximize the power of adaptive learning. While it takes a little time to get the hang of, the use of 5 variablized questions can allow an adapted platform to produce over 100 different versions of those questions! When each question is properly tagged to each objective, strong evidence for student success can be clearly identified. This is where the use of adaptive learning gets exciting! There’s nothing like seeing the results from your hard work developing a properly aligned course from top to bottom.Cartoon of a chalk board with the words

Properly Aligned Lessons

I teach students that the last component they need to develop in the backward design of their course is the actual lesson. After you know the goal, the objectives needed to reach that goal, and how you will assess students’ progress toward that goal, you are now ready to design the lesson. To me, this is the easiest part of the design process. By now the picture is clear and you are best able to develop a lesson that is not only aligned to the goal and objectives of the course but also ensure that you will teach in such a way that will best prepare students for the ways in which you will assess them.

At the end of the day, I am either helping my students succeed or helping them to fail. Too often in academia, we like to pass the buck off to the students. However, this practice is not fair unless we can ensure that our courses are properly aligned and that we are asking students to complete activities and assessments that will help them move up the ladder to reach the ultimate goal of the course.

The use of adaptive learning can allow faculty to design lessons to ensure that all learners are capable of succeeding by properly aligning their courses. However, as you now might be able to more clearly see, the development of effective courses, rather delivered face-to-face, in a hybrid setting, or in an online format, will require the involvement of faculty and, in many cases, the use of instructional designers. Additionally, faculty must be supported with course releases or other appropriate support needed to develop effective courses that can increases student success.

While the use of proper alignment is a critical aspect of course design, the proper use of multimedia principles are also needed. Catch my next blog post for an overview of the multimedia principles and how they are used to design effective courses.

Niki Bray
Instructor & Instructional Designer
School of Health Studies
Physical Education Teacher Education (PETE)
The University of Memphis
Former WCET Fellow on Adaptive Learning

Target image credit: http://hopbeinc.blogspot.com/2012/09/setting-smart-goals.html

Learn more about WCET!

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Leadership From the Place You Stand

Welcome to Kate Jordahl the Director of Strategic Planning & Operations for the California Community Colleges Online Education Initiative. Kate is here to discuss opportunities to help our students and our higher education communities by stepping up to lead. Whether you choose to aim for a leadership role, or lead within your own position (and without a title), Kate’s story is an inspiring one for all of us.

What leadership opportunities will you look for to serve your institution and students?

Thank you Kate for this excellent post and for the beautiful accompanying photographs.

Enjoy the read and enjoy the day,

~Lindsey Downs, WCET

Where do you stand? There are opportunities to help our students from every vantage point.

Hillside with grey clouds

@Kate Jordahl, Hillside One Poem Book No. 3 Wild Geese

I speak to you as an artist, an educator, and an administrator and as someone who has worked in colleges for 40 years starting from my first job in the financial aid office at University of Delaware to positions as classified staff, adjunct faculty, full time faculty, dean, and, now, as a statewide online education leader.

As I think about my journey, what I see consistently is that colleges are in need of leadership and we are all in the position to answer that need.

Leadership is not defined by a role, but by a mindset. My journey from Professor of Photography to Director of Strategic Planning & Operations at the Online Education Initiative (OEI) is both logical and circuitous.

I want to share the benefits of stretching and stepping up to leadership, whether it is changing positions or expanding your faculty role to be a faculty leader. I want to share my story of transitioning from photography faculty to faculty leader to director with the OEI and encourage you to look around and see how you can serve your campuses and students on a larger scale.

Where Can You Make a Difference?

From my experience, this is a win-win opportunity.

“For unparalleled online learning in the 21st century, faculty leadership in transforming 20th-century teaching practices, pedagogy, content, and materials is more important than ever for unlocking student potential and talent to reach higher levels of achievement and a better life in the decades ahead!”

 Martha Kanter, Executive Director, College Promise Campaign & Senior Fellow, New York University former Under Secretary U.S. Department of Education and Chancellor, Foothill-De Anza Community College District

My Commitment to Students Began as a Faculty Member

How does a Photography professor become the Director of Strategic Planning & Operations? Perhaps my path will help you discover your path.

I am a faculty member who loves teaching. I have a Masters of Fine Arts, and I teach photography. I exhibit my photographs and have work in museums. This is a passion. To make photographs, exhibit them, create books and help students follow the path of their creativity is incredibly rewarding. In my classroom, I help students learn how to express themselves with visual language and develop an essential understanding of the impact of images on our culture. I have had amazing experiences over the years in helping my students succeed in the creative realm of photography and then transfer that sense of success to their other studies.

“The illiterates of the future will be ignorant of the use of camera and pen alike.” 

Moholy-Nagy 1936

I have a number of goals as a teacher. Essential to these is that I bring the authenticity of making and sharing my own work as a model to my students. I love the art and techniques of photography, and in my classes, I share this passion with my students. I believe as a photography teacher I have a responsibility to be a working photographer. I strive to inspire my students by sharing my work and my process.

@Kate Jordahl, Cascade, One Poem Book No. 3-Wild Geese

By continuing to learn and grow in photography, I have kept the promise I made in my initial interview at Foothill College – To earn my place in front of the classroom by practicing what I teach.

Within this passion and dedication, I became aware of the larger need and the bigger picture both for my students and my college. For the students, I decided to teach many of my classes online. While I continue to believe that my presence in the on-campus classroom has great value, I needed to meet my students where they were and serve them with quality within their busy lives.

My Commitment to Students Inspired My Administrative Journey

In the midst of this, I had an opportunity to be an interim dean. After my tenure as an interim dean, I was able to return to my faculty position, keeping some of the best parts of being dean and honestly, losing some of the ‘not so’ best parts.

A photo of a lake with two vintage baots, tethered to a long, wooden plank. Behind the boats is lake water, and a bank of the lake with trees.

@Kate Jordahl, Boats, from A Journey to World Heritage

One example of what I found energizing was working across campus in the shared governance arena, and so I joined the Academic Senate and became chair of the Committee for Online Learning (COOL). These projects and others became as rewarding as the work I did in the classroom.

From this work, came many opportunities including being elected to be the faculty representative from Foothill College on the selection of to the common course management system for the California Community Colleges. This solidified my deep interest in online education and the mission I felt in improving online classes for all of our students.

When the opportunity came to join the OEI as Director of Operations, I felt it was the time to stretch, try something new and to find my voice as an administrator. Transitioning to administration is not an easy choice for many of us, especially those of us who love our field, our students and the actual process of teaching. It can be challenging to decide that there is a time to be an administrator.

For me, I found an inspiring and interesting project to work on and, most importantly, I feel that I am in a place to make a difference that would benefit students greatly. As part of the OEI team, I can reach beyond the students in my classroom and help students across the state of California.

How Can You Contribute Your Leadership?

view thorugh a courtyard, gray stone doorway, down into a hallway.

@Kate Jordahl, Through the Courtyard, from A Journey to World Heritage

That is a bit of my story. Now think of your story.

Look around and to see where your passions lie and where you can, either from your position as a teacher or in another position, be a leader and help make education better. How can you be part of the many projects that need doing in addition to teaching? Perhaps it is time to consider what you can do as an administrator.

One of the real benefits I have felt is being able to use many of the skills I honed in the classroom for communication, for explanation and for process with my colleagues and help them do their job. That I can work with colleagues – – faculty, classified staff, and administrators, to make the OEI thrive and therefore help students, is incredibly rewarding.

There will be a time to return to my students and my classroom and at that time I will carry all of my experiences from the OEI with me and will be a better teacher as a result.

“Our faculty are the key to our ability to reach more students and to provide them greater opportunities for economic and social mobility. Providing leadership in moving our community college system toward leveraging education technologies to improve student outcomes is critical for the success of our colleges.”

Eloy Ortiz Oakley
Chancellor, California Community Colleges

Lead from Where You Stand; Keep the Focus on Students

Leadership is the place you stand not the role you have and not the job title you have. I think of all the amazing faculty leaders that I know who make a difference in the lives of students every day. And that by being present, organizing events, by joining the senate or curriculum committee or, when it is time, stepping up to be an administrator, they are doing their authentic work.

I have always been determined whatever my position, to keep my faculty perspective and bring the power of that role and my awareness of students needs with me to every conversation.

It is faculty members with our knowledge of student life, our understanding of the classroom that can bring the faculty voice to the table and be able to speak for all the students and faculty while making things happen on a larger scale.

“I was given the opportunity to assume a leadership role at my college in an interim capacity. Through that experience, I learned that my years of work as a faculty coordinator had prepared me well for the position. I am now leading the transformation of online education at my college. It is exciting, exhilarating, and rewarding.”

 Marsha Reske
Dean Distance Education, Virtual Education Center
American River College

There is no time like the present to look around and see how we can contribute. To explore how we can make our classrooms, our departments, our colleges, our districts and our states better places for our students and to serve our primary passion, to help our students succeed.


Jordahl author photo

Photo by Geir Jordahl

Kate Jordahl
Director of Strategic Planning & Operations
CCC Online Education Initiative (OEI)





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Welcome Back to Fall

Traffic has increased, school supplies are in high demand, pumpkin spiced items have already hit the shelves, the marching bands are rehearsing, and there’s a hint of a chill in the air. We are heading toward my favorite season, fall, which means it’s time for football, switching from iced to hot coffee, finding those scarves and sweaters, and, that it’s time to welcome us all back to school!Four fall leaves on peices of wood.

This year I’m thrilled to celebrate my one-year anniversary as a WCET team member. I am so lucky to be a part of this team. I can’t wait to attend, assist with, and present at the 29th Annual Meeting this year in Denver, CO on October 25-27. There’s still time to join us at the early bird rate.

Finally, I am looking forward to participating in and co-hosting (as WCET) this year’s DLNchat’s with EdSurge Higher Ed, OLC, New Media Consortium, and Tyton Partners. These twitter chats, held twice per month, are engaging, educational, and incredibly fun. Join our professional learning community!

When we discussed putting together a “welcome back post,” Russ mentioned that he is excited for the on-going and new partnerships between WCET and other organizations. All the partnerships have the goal to better serve our members and, ultimately, to better serve students:

  • The Digital Learning Compass work on distance education trends and patterns enters its second year in full partnership with Babson Survey Research Group and e-Literate.
  • The Online Learning Consortium and WCET are exploring ways to help members learn how to tackle issues around accessibility. Watch for panels with experts at both of our upcoming conferences and a survey assessing needs this fall.
  • We want to more formally partner between the State Authorization Network and National Council for State Authorization Reciprocity Agreements to avoid duplication in our work.
  • Several organizations are partnering on a list of questions that students seeking an online program could be asking.
  • We have begun negotiations with UPCEA to add a policy emphasis to their leadership event.

In honor of the start of another fall term, Russ and I chatted with a few of our team members and our Steering Committee and Executive Committee chairs about what they are looking forward to this year.Trees changing colors in the fall

From WCET Leadership

Our Executive Committee Chair, Luke Dowden, told us that:

“I am excited about design thinking and loved the session at WCET’s Summit. For me, increasing my competency in design thinking will produce more successful outcomes for the project I engage in or initiatives I choose to fund.”

In fact, he was so excited about it, he wrote a blog post about it!

Luke Dowden, Director, Office of Distance Learning, University of Louisiana at Lafayette

Nick White, Chair of the WCET Steering Committee, told us that he is excited about “the emerging digital alternative credentials ecosystem, and how that will help shift thinking toward skills and competencies and away from credit hours and classes and PDF/paper transcripts and resumes and all the antiquated artifacts that are so central to our current world.”

-Nick White, Director, Competency Based Learning Solutions, Capella University

From the WCET Team

We also asked the WCET team what they are excited about for this year.

Emerging Technologies

Rosa Calabrese is looking forward to seeing where emerging technologies take higher education, saying “I’m excited to see how mainstream emerging technology will continue to be incorporated into higher education this year. In the past, I have enjoyed seeing projects that revolve around bringing virtual reality, artificial intelligence, blockchain, etc. into not only the classroom, but also into education management more broadly. I’m excited to see how that creativity can make an impact on education this year.” WCET will stay connected with our members about where these (and other exciting technologies) are headed.

-Rosa Calabrese, Manager, Digital and Project Support Services, WCET

Focusing on Students

Wooden scabble tiles with the words

“As our students, teachers, and staff “go back to school” this fall, I am excited about the increasing focus by institutions “on the students,” recognizing not all students come with the same motivations, skills and backgrounds,” says Mollie McGill, WCET’s Director of Programs and Membership.

She continued, “I see more institutions breaking away at siloed functions and identifying ways to make services and resources more readily available to students. Finally, I’m super stoked that WCET is the Backbone organization to the Digital Learning Solution Network. While the Network has some heavy lifting today, I’m excited by the importance and potential impact of the Network.”

– Mollie McGill, Director of Programs and Membership, WCET

WCET Annual Meeting

“Every year around back to school time, I get a little panicked and I don’t even have kids! School buses and thousands of college students will surely disrupt my commute to the office,” says Sherri Artz Gilbert. She continued by reminding us that fall “means we are only few months away from the magical time of year when our members convene at the annual meeting. It really is like a giant family reunion. WCET does much more than the annual meeting but it certainly is the highlight of the year for me. I am in communication with members all year long but getting together really seals the deal of what this Cooperative is all about. I look forward to seeing everyone soon.”

– Sherri Artz Gilbert, Assistant Director, Operations and Member Services, WCET

Megan Raymond continued the theme of being excited for the annual meeting, saying “Fall is always an exciting time around the WCET office as we ramp up for our Annual Meeting.”

Lucky for you, Megan has a sneak peek at the Annual Meeting closing session for 2017: “I am really looking forward to this year’s program which features some new twists and traditional sessions. The closing session is one I’m most looking forward to, Stump the Higher Ed Expert. A panel of esteemed colleagues will receive questions from the audience and a panel of judges will evaluate panelist’s responses. This will be a highly interactive session, should be fun to watch!”

-Megan Raymond, Assistant Director of Programs and Sponsorship, WCET

As you can see, the team can’t wait to see you this fall at the 29th WCET Annual Meeting. Early bird registration ends September 22! Join us in Denver!


State Authorization Network

Terri Taylor Straut is working on a project to update the research on Secretary of State Reporting Requirements for all 50 states for our SAN members.

She told me that “while SARA participation helps our members institutions with the basics of state authorization, it does not have alleviate the need to register with the Secretary of State in states that require a filing. It has historically been very difficult for institutions to know whether or not they need to file. This SAN primary research effort is a step toward greater transparency and communication. “We are all excited about this project which will be a great help for our SAN members.

-Terri Taylor Straut, Senior Research Analyst, WCET

Cheryl Dowd, the Director of the State Authorization Network, is excited about “our growing SAN membership and developing new virtual and face to face interactions, programs, and research to help prepare our 700 institutions efficiently manage state and federal regulatory compliance and state professional licensing requirements.” WCET SAN logo reading The growth of SAN has been incredible, and kudos to Cheryl and company for the outstanding resources and events she’s developed and offered this year!

-Cheryl Dowd, Director, State Authorization Network, WCET

OER /Open Textbooks

Our newest WCET employee, Tanya Spilovoy said: “I’m excited to have the opportunity to interact with even more WCET members as the Z Initiative grows. I know I’ll learn as much from them as they’ll learn from me. And I can’t wait to start planning OER workshops and the Z Squad.”

– Tanya Spilovoy, Director, Open Policy, WCET

Another Great Year

And finally, from Mike Abbiatti, our fearless leader:

“I am excited about the fantastic Annual Meeting agenda, the dynamic Leadership Summit planning, the launch of the Gates Digital Learning Network initiative, and the opportunity to provide another year of leadership support for the nation’s number one provider of responsive excellence in policy, practice and advocacy in technology-enhanced education as we serve our membership in 2017-2018.

-Mike Abbiatti, Executive Director, WCET

So many excited opportunities await us this year! Our team and WCET leadership wish you all well as we head into fall!

What are you excited for? Let us know in the comments below or tweet us @wcet_info #WelcomeBackWCET



Photo of Lindsey Downs


Lindsey Downs
Manager, Communication



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Increasing Online Accessibility and Design Quality in your Online Courses

Thank you to today’s guest blogger, Jackie Luft, Online Accessibility Specialist for Texas Tech Worldwide eLearning. As we start the new academic year, the issue of assuring that our courses are accessible arises anew. Jackie gives us great resources and advice on how to better serve our students.

I also invite you to check out the keynote at WCET’s upcoming Annual Meeting. We kick-off with what is sure to be an outstanding, engaging, and entertaining keynote by Mike Hess, Founder of the Blind Institute of Technology.

Thank you, Jackie and I’ll see everyone else in Denver.

Russ Poulin 

The beginning of the semester brings updates to all of our online courses. Dates are entered, a few new assignments are added, and few are revised and we throw a few assignments in the trash. Maybe there is a textbook with a new edition. Maybe now is a good time to add some Universal Design elements, and consider reviewing your course for online accessibility?

Accessibility – Not Just a Good Idea, It’s the Law!

As you know, providing online accessibility is a federal law. Red banner over a keyboard with words Several lawsuits in the past years have made an impact on the progression towards accessibility in online environments in higher education. The following laws are the basis of the lawsuits, and are used as guidance for online accessibility.

  • Section 504 of the Rehabilitation Act of 1973 states that no qualified student with a disability shall on the basis of disability, “be excluded from participation in, denied the benefits of, or otherwise be subjected to discrimination under any…postsecondary program or activity….”.
  • Title II of the Americans with Disabilities Act of 1990 includes specific requirements for communication, “A public entity shall take appropriate steps to ensure that communications with applicants, participants, members of the public, and companions with disabilities are as effective as communication with others.”

Lawsuits say that, “Accessible means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantial ease of use” (South Carolina Technical College). Most lawsuits emphasis the statements “fully and equally accessible” and “ease of use.” University of Montana – Missoula adds that “individuals with disabilities are able to independently acquire the same information, engage in the same interactions, and enjoy the same services within the same time-frame.”

Can I Just Wait Until I Have a Student with an Accessibility Need?

But what if I don’t have a student with a disability in my class, I never have.” This may be true, but your instructional material needs to be ADA compliant whether you have a student with a disability enrolled or not.

Have you considered the population of students that do not declare their disability? Did you know that implementing ADA standards to your online instructional material helps all students to learn more easily?A yellow note with the outline of an ear drawn on it. The note looks like it is taped to the page.

For example, in an article written by 3Play “Who uses closed captions? Not just for the Deaf or hard of hearing”, according to Television Access Services, 80% of people that use closed captions do not have a hearing disability. Many people also utilize software programs that allow text on a page to be read out loud. Check out the best free text to speech software.

How Can I Address Online Accessibility in My Courses?

Online accessibility and Universal Design of Learning can be overwhelming. Below is a checklist that includes both online accessibility and Universal Design of Learning elements. The list is broken into areas that are typical of an online course. Instructors can use this list as a quick review to decide what to work on throughout the year.

Adding a few of these elements every semester will leave you with a well-designed, inclusive course that will be more accessible to all your students, not just those with disabilities. Note that the items on the list with bold and an asterisk are the federal ADA standards for online content, and the rest are suggestions for Universal Design of learning.

  • Contact information for instructor is easily accessed.
  • Discussion Board includes a place for course questions.
  • Students have email address to ask personal questions.
  • Office hours and phone number are listed.
  • Learning materials are presented in more than one format:
    • Audio lecture with transcripts*,
    • Videos have closed captions*,
    • Readings are in accessible PDF files*,
    • Presentations are accessible*,
    • PowerPoints,
    • Wiki,
    • Blogs, and
    • Visual Aids include pictures that have alt tags (picture descriptions). *
  • Variety of assignments to increase motivation.
  • Course website is organized and consistent from page to page.
  • Links have description of link and do not read “Click Here”. *
  • Navigation tabs are the same on each web page.
  • Color does not convey meaning*.
  • No flashing or blinking content*.
  • Information is accessed with minimum clicks.
  • Every image has an Alt Tag (image description)*.
  • Images are used only to increase understanding of text.
  • Avoid decorative images and borders.
  • Text should be in text format, not image. Example, clipart words*.
  • All fonts are sans-serif*.
  • Avoid color in text that shows meaning.
  • Colors have been checked with Color Contrast Checker.
  • Number of fonts used is minimal, less than four.
  • No text is underlined unless it is a hyperlink.
  • Tables have headings for rows and columns, should be explained in text*.
  • Graphs have a description, either use alt tags or explain in text.
  • Synchronous discussions and chats are at a moderate pace and can be accessed after discussion event, including audio descriptions and synchronized captions*.

Wow, That’s Quite A List. How Do I Proceed?chalkboard with the words

Knowing exactly how to implement all these elements can be a daunting task.

WebAIM is a resource that assists instructors in tips on how to implement accessibility elements. Texas Tech University also provides many resources for online instructors. Online Instructional Materials offers step by step guides on how to make all your courses compliant. On this website you will find information about Seven Steps to an Accessible Documents, How to Check Documents for Accessibility, and Creating Accessible Instructional Videos.

Keep in mind these resources for your online instructional material as you are prepping for your next year of instruction. Not only will your class meet federal guidelines, but you will be making your course accessible to all students, including for those with undeclared disabilities.

Although the list may seem daunting, selecting one area at a time and focusing on that will lead to constant progress towards providing accessible instructional material.

author headshot jackie luft


Jackie Luft
Online Accessibility Specialist
Texas Tech Worldwide eLearning


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Need Your Input: What Matters to You in Counting Distance Education Activities?

It is said that we count what we value.

It is also said that not everything that can be counted has value.

Can you help tell the difference when measuring distance education activities?

The U.S. Department of Education needs your help in discerning what data it should be collecting about distance education and hybrid/blended learning. In a call for comments, they seek advice from interested stakeholders on how they might improve the quality of data collections for its Integrated Postsecondary Education Data System (IPEDS).Reads

WCET is proud to partner with Babson Survey Research Group and e-Literate in examining the IPEDS distance education enrollment data under our joint Digital Learning Compass umbrella. But, today we would like to get your opinions. I will summarize some of the options that they are considering. You can choose to submit a comment on your own. Alternatively, you can send brief comments to me and we will compile them to submit. See details below on how to participate in either option. You don’t need to comment on every item.

The panel discussing proposed changes raised great questions. However, there are times when you can tell that the panel needed more experience on distance education issues. Here’s your chance to help.

So What Has IPEDS Been Collecting To Date?

From the call for comments:

“Since 2012, the IPEDS data collection system collects data on distance education in three survey components: Institutional Characteristics (IC), Completions, and Fall Enrollment (EF). The purpose of these data is to provide useful and meaningful information on distance education offerings and enrollments for consumer, research, and transparency purposes.”

They also include the insightful footnote:

“Although the IPEDS distance education data collection is relatively new, the postsecondary landscape is constantly changing due to advanced and improved technologies.”

Discussion Item #1:  Defining Distance Education

Distance education courses.

IPEDS currently has no definition for a hybrid or blended course. The IPEDS definition of a “Distance Education Course” focuses on almost all of the activity in the course taking place “exclusively via distance education.” The definition is:

“A course in which the instructional content is delivered exclusively via distance education. Requirements for coming to campus for orientation, testing, or academic support services do not exclude a course from being classified as distance education.”

The preliminary recommendation from the panel considering changes is:

“IPEDS should retain its current definitions of exclusively online coursework to maintain longitudinal comparisons with past data collections and should emphasize in the instructions that hybrid courses are not considered by IPEDS as distance education.”

What do you think? How would you improve this definition?

Distance education programs.

The IPEDS definition of a “Distance Education Program” builds on the course definition, seemingly, to focus on exclusively at a distance, as well. The definition is:

“A program for which all the required coursework for program completion is able to be completed via distance education courses.”

The preliminary recommendation from the panel considering changes is:

“Panelists…pointed out that distance education programs are generally approved by accreditors and suggested adding language to the question to clarify that all programs are designed to be completed via distance education. This would eliminate confusion between distance education indicating course-taking practices versus distance education describing the program being offered. They also suggested that NCES review the definitions of distance education programs used by accrediting agencies and consider adopting similar language.”

They are struggling with this one. What would you suggest? Would you include SARA and states in the conversation?

Discussion Item #2: Collecting Distance Education Data in the IPEDS Institutional Characteristics Survey

Distance education levels.

The panel suggests that institutions report their offerings according to the follow table with the newest column on the far right in red:


How would you improve this chart?

Exclusively distance education programs.

See page four of the call for comments for this one. The summary completely confused me. Perhaps you will have better luck. It leads me to the question: I can think of “completely distance education” institutions (those that offer all their courses at a distance), but can you think of an institution that either:

  • Offers all its courses at a distance at the undergraduate level, but not the graduate level?
  • Offers all its courses at a distance at the graduate level, but not the undergraduate level?

Telecommunications systems.

Panelists discussed whether to collect data on the types of technology used in distance education. Their preliminary recommendation is:

“In general, they agreed there was no compelling reason to begin collecting detail on telecommunication systems.”

Do you agree?

Delivery modes.

Panelists discussed whether to collect data on synchronous, asynchronous, or mixed modes of instruction. Their preliminary recommendation is:

“…they pointed out that the mode of delivery varies by course section and collecting this information at the institution level would not be feasible.”

Do you agree?

Discussion Item #3: Collecting Distance Education Data in the IPEDS Completions Survey

Here’s a description of the problem they identified:

“The IPEDS Completions component collects whether the institution offers the full program (as defined by the Classification of Instructional Programs [CIP] code system) and award level through distance education. If more than one program is offered under a CIP code by award level, institutions are instructed to check “yes” to the distance education question if any of the programs are offered as a distance education program. Panelists noted that a constraint of the current format is the inability to identify the number of programs offered as distance education programs if more than one program is offered under a CIP code. They considered several options for categorizing exclusively distance education programs in ways that are better aligned with how institutions organize their programs.”

The options considered:

  • Collect data for each program reported under a CIPE code and award level.
  • Collect data on whether programs are offered in traditional (in-person), online, or hybrid/blended settings.
  • Collect data on the number of programs that are available via distance education.

The preliminary recommendation of the panel is:

“After weighing the burden of collecting the additional data with the benefit it would provide to the public, panelists did not strongly favor modifying the Completions component question about programs offered via distance education.”

Would you like to see completions data or is it too burdensome? If you would like to add it, how would it help you?

Discussion Item #4: Collecting Distance Education in IPEDS Enrollment Surveys

Clarify terminology.

The preliminary recommendation of the panel is:

“Panelists suggested relabeling the category for “enrolled in some but not all distance education courses” to “enrolled in at least one but not all distance education courses” to reduce misunderstandings about “some” distance education coursework on the EF component to mean hybrid courses.”

Collect distance education enrollment in the 12-month Enrollment survey (in addition to the Fall Enrollment survey).

Since some distance education institutions enroll students continuously throughout the year, the current Fall Enrollment report might disadvantage them. The 12-month Enrollment survey might better reflect total institutional enrollments.  The preliminary recommendation of the panel is:

“Panelists did not reach agreement on the value of collecting distance education instructional activity or calculating distance education FTE estimates, given the high burden and questions about who would benefit from these data. Panelists suggested that NCES review information on instructional activity required by accreditors to further assess the burden and feasibility of collecting data on distance education instructional activity.”

It would be great to hear from institutions with non-traditional calendars. How would this option help you? For those with traditional calendars, is this a help or a burden?

Discussion Item #5: Collecting Data on Hybrid/Blended Courses

Collection of hybrid/blended enrollments or activities would be new for IPEDS. It is obvious this discussion could have been aided by someone with more experience with technology-mediated instruction. The preliminary definition and recommendations of the panel are:

“In general, panelists voiced opposition against attempting to use percentage thresholds to define what a hybrid course is and instead suggested using the following definition as a framework for the discussion: hybrid courses are courses that can be taken through some distance education technology that replaces in-classroom seat time. Panelists suggested collecting the number of students enrolled exclusively in hybrid courses, in at least one but not all hybrid courses, or not enrolled in any hybrid courses, by student level and undergraduate degree-seeking status, to mirror the “all, some, or none” format for collecting enrollment in distance education courses.

A panelist also noted that the concept of seat time is not applicable to competency-based education courses, in which the outcome rather than the seat time is the focus, and discussed implementing an exception, or specific instructions, to guide institutions on how institutions should report competency-based education courses.

In general, panelists supported collecting hybrid enrollment in both the EF and E12 components, but RTI encourages additional comments on this topic, particularly with respect to burden on affected institutions.”

What is your recommendation regarding hybrid/blended courses…both in how they are defined and on the value of having such data?

Discussion Item #6: Collecting Additional Distance Education Data

The panel considered:

“The panel was asked to weigh the possibility of adding a new, optional survey component to IPEDS for collecting and reporting consumer-focused distance education information. For example, the panel considered an approach that would focus on attributes related to each CIP code and award level to collect the data for search tools for prospective students.”

The panelists suggested that, if this options is pursued, that consumer focus groups be used to identify useful data items. Additionally, date would be provided in an application provider interface (API) for use by outside organizations.Picture of a hand with a watch and a pen. The words

Now It’s Your Turn: How to Respond

Again, you can respond to any or all the items. You have two options:

  • You can respond directly. Send your comments to Janice Kelly-Reid, IPEDS Project Director, at ipedsTRPcomment@rti.org by September 9, 2017. Write a letter citing who you are, your experience with distance education and/or hybrid/blended education, the items on which you wish to comment, and your recommendations on those items.
  • You can send me comments. I will collect comments and put them into a single response. Send your comments to me at rpoulin@wiche.edu by August 31, 2017. In your comment let me know who you are, your institution/organization, your experience with distance education and/or hybrid/blended education, the items on which you wish to comment, and your recommendations on those items. Please write in complete sentences. I will share this official comment publicly.

Let’s make sure that whatever we count, that it makes sense and is useful. Your input will help assure that outcome.

Thank you,Photo of Russ Poulin


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

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Federal Student Complaint Requirements – Is Your Institution in Compliance Today?

Does your institution have a well designed, easily understood, and compliant complaint process? Today we welcome Cheryl Dowd, Director of the State Authorization Network, and Jennifer L. Parks, Director, Midwestern State Authorization Reciprocity Agreement (M-SARA), to review the federal student complaint requirements. They also provide recommendations for implementation of the complaint process notification and review the SARA student complaint process.

Thank you Cheryl and Jennifer for your helpful post and support!

Enjoy the read and enjoy your day,

~Lindsey Downs, WCET

The complaint process for students can be very confusing and complex. The institution’s goal should be a “student friendly” explanation of the complaint process and MUST include the contact information for the institution’s accreditor and location of the appropriate state agency for the student’s complaint.

In 2010, when the first set of Federal regulations for State authorization of distance education were released, and then ultimately vacated by the courts, there was another important regulation released. Another part of the “program integrity” regulatory changes was not vacated and remains enforceable for compliance by institutions.

Do you all remember §34 CFR 668.43 (b)?

This regulation requires institutions to notify all current and prospective students of the process and contact information for filing complaints. Now that the State Authorization Reciprocity Agreement (SARA) is the state compliance mechanism for many institutions for their out-of-state activities, additional questions about the impact of SARA on this regulation have been raised. In this post we will address the requirements, offer direction for implementation, and share more information about the SARA complaint process.

Two light yellow question marks

What Does the Regulation Say?

Let’s start with the regulation itself:

  • 668.43 (b) Institutional Information

(b) The institution must make available for review to any enrolled or prospective student upon request, a copy of the documents describing the institution’s accreditation and its State, Federal, or tribal approval or licensing. The institution must also provide its students or prospective students with contact information for filing complaints with its accreditor and with its State approval or licensing entity and any other relevant State official or agency that would appropriately handle a student’s complaint.

 A July 2011 WCET blog post, Federal Student Complaint Regulations – Common Misconceptions, included a helpful chart. The chart breaks down the requirements provided in this regulation. In essence, there are three main points the institution must follow related to notification of a complaint process.

  1. The information is to be for Enrolled AND Prospective Students.
  2. The information is for BOTH face to face students AND online students.
  3. Contact information must include where to file a complaint with the institution’s:
  4. Accreditor, AND
  5. Appropriate state approval entity (including SARA Portal Agency).
    • Do you also remember 34 CFR 600.9 (a) (1)? This part of the “program integrity” regulatory changes of 2010 also remains enforceable and requires states to have a “process to review and appropriately act on complaints concerning the institution…….”.

You may wonder, what type of complaints are we talking about here? This process refers to the student’s available recourse if the student has exhausted all possible avenues for complaints at the institution related to consumer protection and the issue has not been resolved to the student’s satisfaction. There are also rare circumstances in which a student may take a complaint to a state entity if the institution has been non-responsive, abusive to the student, or otherwise has lost the confidence of the student. The issues that could be reviewed outside of the institution do NOT typically include issues related to grade disputes or student conduct. The state entities that process these inquiries are well-versed on when to take a complaint or refer a student back to the college or university.

Suggestions for implementation of the complaint process notification:

  • Determine your institution’s best communication avenues/locations (i.e. website etc.) so that information is easily accessible for all prospective and enrolled students.
    • A suggestion from the blog, previously mentioned above, indicated that you may wish to work with your financial aid and admissions offices. These offices are also required to provide information for current and prospective students. Integration of the notifications may provide a more efficient path to reach enrolled and prospective students.
  • Write a clear and “student friendly” description of the institution’s complaint process and under what circumstances a student may seek additional recourse outside of the institution.
    • We recommend that you specifically indicate that the student must complete the institution’s own complaint process before seeking external resolution of the issue.
  • If this notice is used in multiple locations, use the exact same notice to eliminate the possibility of ambiguity or conflicting language.
  • Provide the contact information for filing a complaint with your institution’s accrediting agency.
  • If your institution is a SARA institution, indicate that students should file their complaints with the SARA State Portal Entity for the home state of your institution, unless the student is located in California or Massachusetts. If the student is located in California or Massachusetts, indicate the location for complaints in those states as provided in the list of state contacts (*note that these are the remaining states that are non-SARA and you should update as that status may change).
    • Provide the contact information for filing complaints with the specific SARA State Portal Entity for the home state of your institution. (The SARA complaint process is described below)
    • Although the SARA State Portal Entity is the correct location for the student to file a complaint, it may be best practices to provide the contact information for all state contacts for filing complaints should the student wish to inquire there.
  • If your institutions is NOT a SARA institution, indicate that the student may choose to file a complaint with his or her state of residence and provide the list of state contacts.
  • Please note these caveats when providing the state contacts for the state agencies for filing complaints in the states your institution offers activity:
    • We do not suggest linking to the SHEEO list as it has not been updated.
    • The state contacts list we provide here is date stamped and may be used for reference. Please remember that the contacts you provide should be reviewed on a periodic basis to guarantee that they are current.
    • Currently there is no agency for complaints in California for public or non-profit out-of-state institutions. SAN will continue to pursue an answer.
  • Periodically review your notification and contact lists to ensure that they are up to date and that the language is clear.

SARA Complaint Process:

Three blocks with the numbers 1, 2, 3One of the most beneficial outcomes of the State Authorization Reciprocity Agreement (SARA) is that it streamlines the path student complaints follow when the student and the institution are located in different states. The SARA student complaint process incorporates processes outlined in Federal code and required by accreditors but also clarifies in which state a student can file a complaint that rises above the institutional level.

As described previously, each state is required under §34 CFR 600.9 (a) (1) to have an appropriate process and entity to address student consumer complaints about the institution in which a student is or was previously enrolled. When a state and a school agree to participate in SARA, they also agree that when a student complaint rises to the state level for resolution, it is ultimately resolved by the SARA state portal entity in the state in which the institution is located. As with the general student complaint process, grade disputes and student conduct complaints cannot be addressed through the SARA process. In the SARA process, those types of complaints are resolved at the institutional level.

Information about filing complaints through the SARA process:

Every SARA institution is required to provide information on its institutional website explaining how students who attend the institution from another state via distance education can appeal a complaint that has exhausted the institutional complaint process. If after exhausting the institutional process a student feels a complaint has still not been adequately addressed, the student can file a complaint with the SARA State Portal Entity of the state in which the institution is located. The state portal entity is required to provide information on its portal entity website explaining how students located in other SARA states but attending SARA institutions in that state can escalate complaints to the state portal entity.

More detailed information about the SARA student complaint process can also be found on the NC-SARA website and in the NC-SARA manual.

Process: Student files complaint. Either Complaint is resolved at the institution level and the process ends, with no notification to NC SARA or State Portal Agency OR, if complaint is not resolved student may appeal to portal agency in the home state of the institution. When student appeals, the home state portal notifies NC Sara and the host state where student is located of the appealed complaint. Home state portal agencies must report status of complaints to NC Sara quarterly.

Suggestions for implementation of SARA complaint process notification:

  • Familiarize institutional compliance and state authorization personnel with the SARA complaint process.
  • Provide language, diagrams and relevant links to help students understand how the SARA (post-institutional) complaint process is different from the process for students attending the institution on campus, via distance education in the same state, or via distance education from a non-SARA state.
    • Provide this information in the same places all other student complaint information is provided.
    • Schedule periodic reviews of SARA policies and website content to make sure all information is up to date and that all links work properly.


If you are with an institution, you will want to check at your institution to see what, where, and how the institution is notifying students about its complaint process. The bottom line that you may wish to share with others at your institution includes the following:

  1. The institution is required by federal regulation, 34 CFR 668.43 (b), to provide contact information for filing complaints if the institution wishes to participate in Title IV funding (and most institutions do).
  2. The institution MUST supply current and prospective students with the contact information for the appropriate state agency for complaints and contact information for the institution’s accrediting body.
    • The contact information MUST be accessible to all students regardless of whether the student is taking courses face to face or online.
  3. If the institution participates in SARA, the institution should clearly explain the complaint process for students located in other SARA states and MUST direct them to the portal entity that authorizes the institution.

The WCET State Authorization Network (SAN) and National Council – State Authorization Reciprocity Agreements (NC-SARA) are available to support your institution in its research and best practices for implementation of processes to meet the federal and state regulations for state authorization compliance.


Cheryl Dowd
Cheryl Dowd
Director, State Authorization Network



J Parks author photo

Jennifer L. Parks
Director, Midwestern State Authorization Reciprocity Agreement (M-SARA)
Midwestern Higher Education Compact (MHEC)




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Converting Experience into Credit: Lessons in Serving Military-related (or Any) Students

When we asked Sara Appel to write a guest blog post for us, we did not know we would also be advocating for increased GI Bill benefits, but it fits in with the unexpected military theme. But, it’s more than that. logo of the Midwestern Higher Education CompactSara’s project for the Midwestern Higher Education Compact provides us with great lessons in converting experience into credit. Some of it can be applied to any student, but we are glad better assist those who served in the armed forces. Thank you to Sara for sharing what she’s learned.

Russ Poulin, WCET

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The mission of the Multi-State Collaborative on Military Credit (MCMC) is to facilitate an interstate partnership of 13 states, and to translate competencies acquired by military-affiliated students through military training and experiences toward college credentials. States exchange information and share best practices in the areas of articulation of credit, certification and licensure, communication, and data and technology.Number 3 in a circle

Having worked in these areas what lessons have we learned? Well, there are three major ones.

Lesson 1: You Don’t Have to Take It All 

Many military-affiliated students are under the assumption that postsecondary institutions will or should accept all the American Council on Education’s military credit recommendations found on their Joint Services Transcript (JST).[i] Unfortunately, there are some for-profit institutions that practice this. This practice may provide immediate gratification for those students, but it may harm them in the long-run.

Here’s why it’s important not to accept all the recommended credits found on the student’s JST. Too many of these credits end up as undistributed credit. If there are an exorbitant number of such credits, it can hinder Satisfactory Academic Progress (SAP) and could interfere with other forms of financial aid. This is especially true should the student use grants or scholarships while saving their GI Bill® for future education endeavors.

If and when the student comes in to discuss their JST, explain why all of those credits weren’t accepted (perhaps it’s institutional policy that limits the number, they wouldn’t help in their degree program, etc.), educate them about SAP, and the importance of following their degree plan. If the student doesn’t come in to talk about their credit transfer, send them a letter explaining why and offer to speak to them about it in detail. Many military-affiliated students are first-generation college students and aren’t aware of all the ins and outs of the postsecondary maze.

Here’s something else…it’s not only first-generation students or military-affiliated students who need help with academic literacy; it’s the majority of students.

Lesson 2: Alternative Credit Needs to Be on the Menu

Soldiers carrying packs walking near waterWe all have heard those terrible stories of veterans who have gone to college to work on a degree in their military occupation only to have to take basic courses they have already completed and are well skilled in. For example, someone who was a 92G (Foodservice) in the Army who is required to take basic food prep or nutrition. Or the 68W (Health Care Specialist) pursuing nursing, who is required to take a class on anatomy or how to insert an IV when he or she has already had that training.

Can you imagine their frustration?

Successful postsecondary retention requires recognition of learning that occurs outside the classroom.  Recognition of non-collegiate learning leads to feelings of academic competence, empowerment, and motivation (Burr, Burr, & Novak, 1999; Rendon, 1993; Zucker, 1999). Viewed in this context, validation of non-collegiate learning is most effective when offered early in the student’s academic career.

Consistent with the notion of institutional recognition of learning outside the classroom, the concept of “mattering” (Schlossberg, 1989) suggests that students need to believe that an institution cares about them before they can feel comfortable participating in academic and social behavior. This participation ultimately leads to higher retention rates. Theories of prior learning recognition and institutional caring support Chaves’ (2006) conclusion that it is important to validate adult students’ learning outside and within the classroom and to foster a connection between the students, the faculty, and college.

When postsecondary institutions recognize prior learning, practice institutional mattering, and provide opportunities to validate experiential learning, military-affiliated students may be more likely to invest in their formal education. So how can we, at postsecondary institutions, avoid frustrating students and aid in retention? Below are five methods.

Lesson 3: Communicate and Make Personal Connections

At MCMC we have discovered, perhaps the most valuable lesson is communicating with others and making personal connections.

instructor hands two military students an assignment

On the campus, find faculty who have been in the military and ask them to sit on a board for military-affiliated students. Work with your campus’s Student Veterans of America chapter and if you don’t have one, see if one can be started.

Make sure faculty, staff, and military- affiliated students know who the military point of contact is on their campus to help with resources and answering questions.

Work with branches of the military near your university, talk with the education officer, and offer to provide workshops for those thinking about going to college or starting their college again after stopping out. Get to know your State Authorizing Agency as they can be a great resource on anything from special programs for military-affiliated students to data and statistics.

By selecting one or all of the above lessons learned you will be on the road to improving your campus climate for military-affiliated students. Not sure where to start or know how your campus is currently doing and perhaps want to find those gaps to fill? The Council for the Advancement of Standards in Higher Education (CAS) has a specific assessment designed for Veterans and Military Programs and Services. This evaluation tool provides individuals and institutions with a means for assessing programs and services based on these standards.

Author headshot


Sara E. Appel
Project Coordinator, Multi-State Collaborative on Military Credit
Midwestern Higher Education Compact




[i] The Air Force has the Community College of the Air Force and students typically aren’t facing the same challenges in credit acceptance as other branches; they have their own transcript and aren’t part of the JST.


Burr, P. L., Burr, R. M., & Novak, L. F. (1999). Student retention is more complicated than
merely keeping the students you have today: Toward a “seamless retention theory.”
Journal of College Student Retention, 1(3), 239-253.

Chaves, C. (2006). Involvement, development, and retention: Theoretical foundations and potential extensions for adult community college students. Community College Review, 34(2), 139-152.

Rendon, L. I. (1993). Validating culturally diverse students: Toward a new model of learning and student development. Washington, D.C: Office of Educational Research and Improvement.

Schlossberg, N. K (1989). Marginality and mattering: Key issues in building community. New Directions for Student Services, 48, 5-15.

Zucker, B. J., Johnson, C. C., & Flint, T. A. (1999). Prior learning assessment. A guidebook to
American institutional practices.
Chicago: The Council for Adult and Experiential Learning (CAEL).

Photo: U.S. Air Force photo image/Staff Sgt. Desiree N. Palacios

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