Negotiated Rulemaking: The Complexity of “Regular and Substantive Interaction”

Image of extremely complicated and complex geometry problem, including numbers, shapes, and graphs.

This is the third in our blog post series on the results of the U.S. Department of Education’s negotiated rulemaking process. The first in the series focused an overview of process, issues, and next steps. The second covered rules for state authorization. Today, we focus on definitions that seem like they should be easy, but […]

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Interpreting what is Required for “Regular and Substantive Interaction”

As greater numbers of students move into online and competency-based education programs, we have seen new interest in understanding the Department of Education’s regulations. In particular, faculty and administrators seek to understand how the Department interprets rules requiring courses to include “regular and substantive interaction,” especially in distance and competency-based education. Those of us in […]

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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 […]

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Negotiated Rulemaking: Accreditation, Student Identify Verification, Student Disclosures, and Other Proposed Regulations

PIcture of judge gavel placed beside two books.

This is the fourth and final post in our blog post series on the results of the U.S. Department of Education’s negotiated rulemaking process. You may recall that there were many issues covered by the negotiated rulemaking committee and to our pleasant surprise, consensus was reached. With so many issues, we divided our review of […]

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Negotiated Rulemaking Reaches Consensus: An Overview of Processes, Issues, and Next Steps

Picture of five human fists, joined over a wooden table in the form a fist punch.

In this first of several blogs dedicated to sharing the meaningful outcomes of the three-month negotiated rulemaking sessions, Cheryl Dowd and Russ Poulin announce some exciting news and provide an overall assessment of the process and results from these important sessions. Enjoy! –Erin Walton, contract editor for WCET Consensus was a surprise! That is right, […]

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ED Negotiated Rulemaking: Innovation Subcommittee Completes Its Work and Makes Several Recommendations

Three women and two men are sitting at a table with microphones in front of them. Three of them have the name cards in front of them on end.

The “Distance Learning and Education Innovation” Subcommittee of the current U.S. Department of Education negotiated rulemaking process completed its work last week. While several reports highlighted that there was disagreement on issues, there has been less attention paid to the general agreement the negotiators were reaching on a long list of regulations under consideration. There […]

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ED Negotiated Rulemaking: Thoughts, Updates, and New Position Papers from OLC, UPCEA, & WCET

The Department of Education has a long list of higher education regulations under consideration in its negotiated rulemaking process. As the calendar of meetings winds down, the path to agreement on most issues remains rocky, but not impossible. Lost in the reporting about disagreements has been the (at least modest) progress that has been made […]

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ED Negotiated Rulemaking: Issue Summary and Seeking Your Input

WCET continues to cover the wide-ranging set of rule changes that are being proposed under the U.S. Department of Education’s negotiated rulemaking process. The Department is seeking input on several major changes on issues with special focus on accreditation and how to handle “innovation” in qualifying students for federal financial aid. Examples of what is […]

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ED Negotiated Rulemaking: First Reactions and a Preview

Set of guiding princples in a list: Fairness to all students. Incentivize, don’t punish, institutions for being innovative. Transform quality assurance standards to rely on educational outcomes. Simplify regulations around financial aid program eligibility requirements. Protect student and federal financial aid investments.

A fond welcome and thank you to Van Davis, Foghlam Consulting, for his analysis of what will be discussed in the U.S. Department of Education’s rulemaking process, which begins this week. As you will see, there sure is a lot on their plate! With WCET’s Russ Poulin on one of the subcommittee’s, we will be […]

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