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 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 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

= = = = = = =  = = =

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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What role does research play in EdTech decision-making?

How are edtech related decisions made at your institution? Do your decision makers review research to make decisions about what edtech is selected for use in the classroom? This week we welcome Fiona Hollands from the Teachers College with Columbia University, to discuss the role of research in edtech decisions. Thank you Fiona for this post!

Enjoy the read,


In the spring of 2016, I was invited to participate in a symposium that aimed to bring together a variety of stakeholders – researchers, entrepreneurs, school district and higher education leaders, investors, philanthropists, teachers, and professors. The symposium focused on the role of efficacy research in the development, adoption, and implementation of educational technology. Ten working groups were formed to study various topics to present at a gathering of the entire group in May of this year.

My group was tasked with investigating the role of research in higher education EdTech decision-making. Being a researcher myself, this topic was of particular interest.Quote reads I always wonder whether my work makes any difference to what practitioners do.

My big takeaway from the symposium: we collectively need to find more and better ways to use research to inform decisions about acquiring and using technology in education to improve student outcomes.

The Role of Research

To get things in perspective before honing in on the specific role of research, we set out to understand how EdTech decisions are made in higher education:

  • Who are the stakeholders?
  • Who are the actual decision-makers?
  • Who identifies the needs to be addressed?
  • Where do these decision-makers get their information about EdTech products and trends?
  • What criteria do they use to choose among alternative products and services?
  • How do they evaluate the different options?

We interviewed 52 CIOs, Presidents, Directors of IT, Digital Learning or eLearning, other administrators, and academics who actively participate in EdTech decision-making at their colleges or universities. Our sample included both 2-year and 4-year institutions, publics and privates, for-profits, and non-profits.

The Garbage Can Decision Making Model

Our line of questioning implicitly assumed that EdTech decision-making is rational, that is, it starts with a need and ends with a solution.

In practice, we found that wasn’t always the case. There were a number of situations in which an EdTech administrator came across an EdTech product or service that seemed too appealing to pass up. They purchased the product and then engaged faculty members in trying to figure out how to make it useful in the classroom.

red garbage can

There is a formal name for this type of decision-making – it’s called the garbage can model.

But, for the majority of EdTech decisions described to us, the process did start intentionally with one or more specific educational goals to be addressed – for example, providing individualized math instruction at scale – and proceed to a search for viable solutions.

Final decisions about EdTech acquisitions were most frequently made by administrators. Non-profit institutions usually engaged faculty members and students in testing out different EdTech options and providing input about usability and preferences before making a final selection. This approach helps to create buy-in. Buy-in is conducive to more successful implementation. While a non-profit might spend 1-3 years (and a lot of stakeholder time) choosing among 2-3 platform options that really aren’t that dissimilar from each other, for-profits sometimes reported making important EdTech decisions around a C-suite table in the course of one afternoon. If faculty and student input were sought, it was generally after the decision was made.

One interviewee at a for-profit institution amusingly contrasted non-profit and for-profit decision-making as follows: “Our previous president was the Chancellor of University of Maine’s system. When he came here, he said the difference was like [the difference] between driving a cruise ship and driving a sports car. Kind of good and bad. You could make bad decisions really quickly.”

There’s probably a happy medium that allows the institution to build buy-in and capacity for a technology adoption without being an excessive drain on time and resources.

Choosing Between EdTech Options

On average, decision-makers considered six distinct aspects of EdTech products during the selection process. These fell into the following five categories:

Category of decision criteria

% of interviews in which criteria in this category were listed

Features and functionality


Feasibility of implementation


Cost or Return-on-Investment considerations


User experience or usability


Vendor characteristics


Notes: There were 44 interviews in which criteria for making a specific EdTech decision were elicited. In total, 277 criteria were named by interviewees and these were initially sorted into 88 categories. Subsequently, these were further aggregated into the 5 categories shown above.

No-one listed the existence of research about the product’s impact on student outcomes as a criterion for choosing among the possible solution options. However, everyone claimed to do research about EdTech and many collected significant amounts of data to inform their decisions.

What they meant by “doing research” varied. In all cases, this included an ongoing effort to stay abreast of EdTech developments and applications through constant interaction with colleagues at conferences, via social media and internet sources, and by reading EdTech news and publications. Peer-reviewed academic journals were listed as a source of EdTech information in only 9% of interviews (which is one reason I am writing this blog post instead of revising and resubmitting a journal article I wrote previously).

Decision-makers Prefer Local Evidence

One explanation given for lack of reliance on existing research evidence is that the results of studies conducted in different contexts and with different student and faculty populations may not be relevant in the decision-maker’s own context. Instead, decision-makers prefer to collect their own local evidence. Picture of a horseFor example, for almost 40% of the EdTech decisions discussed in our interviews, the college or university engaged in a pilot of one or more alternative products. Typically, this would involve asking a portion of the faculty to use the product in regular classes during the semester to assess pedagogical usefulness, ease of use, and feasibility of implementation. In a few cases (11%), impact on student engagement, completion, retention, or other student outcomes was also investigated at this stage. Alarmingly, impact on actual learning was rarely discussed at this point. And, curiously, impact on student outcomes was far more often assessed after a product had been acquired and implemented.  While these data may be helpful at that point to make decisions about whether to continue using a product, it might be wise to put this horse before the initial purchasing cart.


One of the consequences of this preference for local evidence is that the same products are simultaneously being piloted at many institutions, at no small cost, without the results being shared. Context is certainly critical, but it is likely that colleges and universities have an exaggerated sense of their uniqueness when it comes to end-user needs for and reactions to technology. A second issue is that most of these pilots are not particularly rigorous in terms of assessing whether students using one technology solution perform better academically than those using another solution, or no technology at all.

Moving Forward

It may be the case that pilots provide more value in building buy-in and gradually ramping up implementation capacity than in assessing technology’s contribution to improved learning. To achieve the latter, more rigorous studies will be needed, ideally with comparison groups. It might be helpful for someone – perhaps like WCET – to provide guidelines for robust design of EdTech pilot studies. It would also be helpful to establish an online repository for members to share the results of their internal EdTech studies. If study results are accompanied by descriptions of the implementation context and of the types of students and faculty involved, other institutions can look for “near peers” to gauge the potential for a technology product’s success at their own site.

More detailed findings and recommendations from our study and some resources that EdTech decision-makers shared with us are available at



Fiona Hollands
Center for Benefit-Cost Studies of Education
Teachers College, Columbia University





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Let’s Not Let Them Down – Stories from Veterans on Housing Allowance

Following up on the Housing Allowance for Veteran Distance Ed

“The technology has advanced, but not the laws” says one of the veterans, Aaron Slatton, whom we spoke with this week regarding the Basic Housing Allowance reduction imposed on veterans who take classes fully online. “Simply put,” he said, “there is less benefit.”

The GI Bill was put in place to provide our service men and women certain benefits to help them resume a civilian life, including housing benefits while they are completing their education. President Roosevelt signing the GI Bill surrounded by others

When signing the GI Bill, President Franklin D. Roosevelt said that this bill let our men and women in the military know that we “do not intend to let them down” (1944).

Our veterans deserve all the benefits that were guaranteed by this (and other, similar) legislation. I was happy to see Congress making additional updates to the bill, guaranteeing expanded benefits and opportunities for these brave men and women. However, as WCET reported last week, they missed a vital chance to correct a major issue in distance education for this student population.

GI Bill Reduction for Housing

Veterans of the U.S. armed services are eligible for funding to pay for tuition, fees, books and supplies, and a Basic Allowance for Housing (BAH) while pursuing postsecondary education, but ONLY IF their courses are taken fully on campus. If their courses are online, the BAH is cut in half (see (c)(1)(B)(3)).

After sharing the story of how the BAH decrease has affected veteran Danny Stuckey last week, WCET has received several more stories. Today, I’d like to share some of these.

Housing Rule Impact

My Housing Payment Doesn’t Change

Aaron Slatton, the U.S. Marine who I mentioned earlier, says that the BAH rule strongly affected him when he was using his GI Bill benefits, and also impacts the students he works with daily as a Veterans Affairs Specialist with Indiana Tech.

“There are many students who are forced to take an on-campus class so that they can collect the full amount of BAH. Distance Ed classes have the same content and amount of work that on campus classes have. It really makes no logical sense that I get paid less than an on-campus Vet, considering we both do the same amount of work. Either way, my housing payment doesn’t change. I don’t have a cheaper payment because I don’t go to school.”

Aaron is pursuing his MBA and also works full time to support his family, including his three-month-old daughter. Currently his family is only receiving half their BAH because to balance working fulltime and school, he takes his classes online.

A Student Quits College

Deborah Rydman, the Career Services Coordinator and VA School Verifying Official for University of Alaska Southeast, sent us several stories, including the story of a veteran she worked with who was faced severe consequences due to the BAH rule. He has stopped taking classes.

Deborah reminds us that life is different in rural Alaska: “I worked with one student last year who {was} taking our Business Administration degree program but lives over 1,000 miles away from our campus. He expressed frustration on how he couldn’t find a class at one of our branch campuses near where he lives for a semester, and was discouraged that he wouldn’t be able to complete his degree… He stopped taking classes after last fall semester.”

Online Might Be the Only Option

Another veteran brought up a very important detail: sometimes, whether a student takes a course online or on-campus, really isn’t their decision.

“Many universities…are dropping on-campus courses in favor of online courses. If I had it my way, I would take nothing but on-campus courses. Unfortunately, UAS (University of Alaska Southeast) students are no longer able to complete a degree without being forced to take some, or most of those required classes, online.

The clause of required time on campus for full benefits seems arbitrary. The only people it hurts are the veterans attempting to take advantage of what they have earned (by putting their life and mental health at risk). Quotes reads: The payout should be the same for each and every veteran that earned the GI Bill"The option to take on-campus courses is becoming increasingly difficult… The payout should be the same for each and every veteran that earned the GI Bill. No matter the method at which one chooses to use it.”

Students Waste Their Time and Benefits on Unneeded Courses

Another student struggled to balance school, GI Bill requirements and her family’s needs. “I have struggled with that situation because with the upper credits I needed to graduate… I often had to take classes that I was not necessarily interested in/focused on and had to sacrifice a very relevant course for one that was offered in the school. …

Impacts to Family

Several veterans told us that their family suffered because of the decrease in their housing allowance. One said: “I cannot afford to send my son to daycare and pay our bills with the limited BAH. Although I am a full-time student the only time I can do any of my coursework is after 7 PM. I go to school full-time only because that is the only way I get BAH “

Another added, “as a stay at home dad, finding time to do fatherly things and pay bills was a challenge. My job demands much of my time and commuting makes managing time a challenge. A lower BAH means restricting me to live in either a further location, which increases commute time, or living nearer and spending more money, thereby restricting my cost of living.”

A veteran and working mother told us, “it makes things difficult as a mom of four to work full-time, cook meals and give them full attention while going to class. It would be easier to be able to have help but I can’t afford that.”

Others told us that they were forced to move their families to different states so they could go to school but receive the full BAH.

Recommendations from Veterans

We have almost 300 additional responses to our questions regarding the impact of the BAH reduction on our veterans. The students discussed that the BAH rule impact has forced them to take student loans, not use their promised GI Bill benefits, reconsider their choice of school due to cost of living, extended length of time to degree completion, and caused severe stress to them individually and to their families. American Public University System (APUS) collected these responses from their students.

The veterans we spoke with have several recommendations when it comes to changing this rule:

  • “The BAH should be taken off pro-ration for number of days attended and that individuals get paid the full benefit regardless of being an online or on-campus student.”
  • Students should receive the “full BAH with the housing cost based off the local university campus closest to the student.”
  • “As long as the student-veteran is classified as “full-time” at a university/college then they should receive 100% BAH. Most veterans don’t have the luxury of going to a traditional “brick and mortar” school and not work.  We have earned the benefits inherent in the Veteran’s education benefits.
  • “I think the rule works fine for those that are just taking classes on the side, while also having regular employment. However; I think that those who choose to go to school full time without an additional job deserve the full bah stipend.”
  • “Base the BAH on the course load and the zip code the student lives.”
  • “We deserve it.”

I was saddened by the survey comments that said they weren’t sure their stories would make a difference. Many of them feel that no one cares that they face this additional challenge while trying to work and achieve their degree.

Let’s not let them down – It’s your turn to act.

Help us by contacting your representative or senator and asking them to address this issue as these bills move forward. We included a letter template in our previous blog post.

House of Representative members by state:


Time is short, the House will act this week and the Senate plans to follow closely behind.

Photo of Lindsey Downs
Lindsey Downs
Manager, Communications
WCET – WICHE Cooperative for Educational Technologies


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




Roosevelt, Franklin D. (1944). Statement on Signing the G.I. Bill. The American Presidency Project. Retrieved from

FDR Signing GI Bill Photo FDR Library Photo Collection, NPx 64-269

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In Defense of the LMS

Many of us have worked with Learning Management System (LMS)s in one way or another, as administrators, instructors, support, assistants, or students. And, through working with these platforms, many of us end up strongly disliking them.

This week we welcome Sasha Thackaberry from Southern New Hampshire University to discuss this love/hate relationship between higher education and LMSs and provide new insights on using the tools in more practical and successful ways.

Enjoy the read!


Ah, the much-maligned Learning Management System (LMS), the technology we collectively love to hate. It’s often bulky, either feature-bloated or feature-wanting, and has been created seemingly without hiring any user experience designers. For years we’ve been wanting to get rid of it. No one actually likes it. We put up with it. We collectively sigh and move along with our day.

Instead, we propose innovative solutions beyond the LMS—a future learner-centered technology ecosystem that lies just beyond reach wherein we extend a non-LMS platform through rich interoperability. We dream of deploying best-in-class integrated solutions for all of our learning and teaching needs—from basic assignment and assessment management to social interactions, internet world connectedcontent curation environments, adaptive learning, Competency-Based Education (CBE) systems and Learning Object Repositories (LOR.) This idealized future has not been largely adopted in higher education, and for good reasons, which we’ll explore later.

Maybe, instead of hating on this category of technology of admittedly legacy origin, we might try to evolve our ecosystems more practically, both within and beyond the LMS. This defense of the LMS is a proposal for a pragmatic path forward.

Realizing the Next Generation Digital Learning Environment (NGDLE)

The Next Generation Digital Learning Environment (NGDLE) vision proposed by Malcolm Brown, Joanne Dehoney, and Nancy Millichap has been the point of reference for most conversations surrounding this improved, learner-centered technology-enabled future. Other versions of this concept have also been proposed. This concept is based on five domains: interoperability and integration, personalization, analytics, advising and learning assessment, collaboration, and accessibility and universal design. These are really good domains. The NGDLE is a solid and innovative framework from which to view a future, more dynamic learning ecosystem.

Many groups have worked to bring this future closer to reality, like EDUCAUSE through thought leadership, IMS Global through the creation of open interoperability standards, WCET by facilitating the conversation, among others. There have been innovative projects like TEx from the University of Texas System, focusing on a user-centered mobile-based experience, the app store at the University of North Carolina campuses, and systems designed exclusively for CBE like Brainstorm by Ellucian (now closed), Sagence Learning and Fidelis’s LRM solution.

There have even arguably been some success stories regarding a post-LMS world. Western Governors University, for example, has eschewed the LMS in favor of an extended Salesforce platform and usage of curated courseware. However, these examples have still been largely isolated in the marketplace, and have not gained significant traction. It remains that most colleges and universities prefer, at least for the moment, to stick with a traditional LMS. It may be cost, it may be the challenge of overcoming inertia and a graphic reads "The Practical Facts: 1. Most colleges use LMSs. 2. But not enthusiastically"feeling of LMS-related powerlessness, it may be lack of internal development capacity.

It may be a lot of things, but the practical fact remains—

  • most colleges and universities utilize LMSs and
  • most folks who work with them are not particularly enthusiastic about them.

And Another Thing We Learned from MOOCs

One of the things we learned from MOOCs has been that consumer-grade technology can be utilized for learning at scale, for relatively low cost. Even more importantly it can make the learner-as-user experience significantly less painful. The technology should fade into the background. It should support a seamless learning experience wherein the learner takes center stage. Despite the trough of disillusionment that MOOCs are currently experiencing, the fact remains that they are here, they are massive, and learners are voluntarily engaging with them, despite having little skin in the game. The large MOOC engines did hire user experience designers (they arguably should have also hired more instructional designers; a MOOC I am currently taking has immeasurable objectives like “understand”).

Why was this possible? They were freed from the assumptions of legacy systems, and, apart from the cMOOCs (“the originals”) they were largely developed by non-learning specialists who were able to look at the learning environment differently. This is one of the many disruptions of MOOCs, the fallout of which has not yet been fully realized.

Practically Speaking: The Reality on the Ground

Why is there this dissonance between what we in edtech largely agreed was needed decades ago and what has been realized in colleges and universities? Part of this dissonance is a cultural conversation. Engaging in large-scale system changes that involve students and faculty is difficult, time consuming, and expensive. Many institutions do not have adequate funding to cover the cost of simultaneously running two systems while weaning themselves off of the previous one. Most LMS moves in the past five years have been precipitated by the deprecation of other LMSs like Angel and eCollege. At least a few of these changes have been affected by statewide discounts on specific LMSs or other variables like membership in Unizin.

In many cases, the discussions surrounding the NGDLE underestimate the power of status quo in LMS usage patterns. In institutions where the LMS is an add-on to supplement on-ground courses, or wherein online programs have cropped up on an ad hoc basis, it is hard to make the cultural argument for the rest of the institution that the disruption is worth it. Most online courses and programs are still instructor designed and developed; a one-to-many model is not the norm. And in cases where there is a strong online division within a larger institution, there is still the powerful fear of “first, do no harm,” with the perception of opportunity cost for student success being larger than reality.

So what are we to do?

Pragmatically Speaking: Proposing a Middle Ground for Realizing the NGDLE

I propose that institutions should evolve the LMS from within. As we undergo such an endeavor, it will be paramount to acknowledge that we are not the users. Learners are the primary users. Faculty are secondary users. And the rest of us should support. Often we have no idea what the user experience really is because we don’t test it, or we don’t ask good enough survey questions to get any actionable data that goes beyond surface inquiries. If we do get actionable data, it is rare that action is actually taken. This proposed pragmatic approach relies upon a consistent focus on the learner-as-user.

There are various functional groupings that are present in the learner-experience first. I will not address here the invisible systems that support the student experience.. Within the learning experience itself there are categories like gradebook management, assignment submission, testing and quizzing, Content Management Systems (CMS,) or preferably Learning Object Repositories (LORs), and content authoring tools. Social engagement tools are needed, as are content curation and collaboration spaces. Outside of the immediate learning environment there are needs such as advising support systems and apps, enrollment activities and bookstore purchasing and provisioning.

All of these functional groupings can be plotted in reference to whether the LMS has those native features or whether the system would need to be extended to support them, and whether the LMS supports that functional grouping in a shallow or deep way. Institutional needs will vary on both spectrums, and conceptualizing of building the NGDLE on an LMS in this way is practical; it has the added benefit of being able to get a better learning environment to learners sooner.

Institutions would then be able to both evaluate LMSs, or other systems, with their needs in mind. If there are functional groupings that a given institution knows they want to use in a deep capacity, that institution may want to look for an LMS that has more of that functionality native to the system in a deeper manner. Likewise if there is lightweight usage, having that feature as a native functionality is a bonus because it is then not necessary to extend it. For needs that may be deeper, and which the LMS does not support natively well, that is where the system would intentionally be extended, preferably through standards-based, plug-and-play integrations, but also through more custom APIs if necessary (quantity and quality of data being both necessary.)  Institutions should then avoid like the plague extending their LMS to get shallow functionality, particularly that which is rarely used.

A square, broken into four sections. At the top, "Native Functionality," the left "shallow capability," the right "Deep Capability," and the bottom "extended functionality." There is a smiley face icon in the upper, right. A circle with a slash through it on the lower, left.

Some institutions still largely utilize their LMS as a document repository and for grades; for online courses this usage expands to the deathly hallows of the discussion boards, for assignment submission and for formative and in some cases summative objective assessments. This relatively shallow usage does not dictate a robust ecosystem, rather it requires a more user-friendly experience. This is a more culturally and fiscally pragmatic approach with which to analyze appropriate systems.

The Future: LMS as a Platform

But we still want to get to our ultimate goal—a highly interoperable ecosystem with a best-in-class, learner-as-user experience. Given our current, collective limitations, what are we to do? Instead of searching out alternative platforms, we might partner with LMSs to reconceptualize the LMS as a platform. In many ways, the LMS is already beginning to evolve in this direction. Canvas has their App Store, which is a more individual faculty-driven model. John Baker of D2L recently utilized the oft-referenced Lego analogy. LMSs in general are moving away from individual building blocks or custom integrations towards open standards like LTI, but the robustness of that interoperability is still inconsistent across what version of LTI their product meets. LMSs are integrating more seamless synchronous video functionality – both Canvas and Brightspace have synchronous tools built on Big Blue Button.

An LMS will never out-Twitter Twitter, or out-Facebook Facebook, or indeed even come close to a functional version of those types of social platforms. And they shouldn’t try to. Rather we should work towards interoperability—even of these consumer tools—and do our level best (and more) to respect student data privacy. Putting the selection of input streams and publishing streams into the hands of learners will facilitate the robust nature of the learner-as-user experience. connected computers and mapIt will also embed within the educational experience the expectation of a partnership between learning institution and learner, enabling a relationship that will persist beyond graduation and alumni activities as we move to a world where continual education is necessary.

This is just the beginning of that evolution. No one likes the walled garden, but there’s not a plausible open playground yet. For many, if not most learners, we need to Chipotle the LMS. We need a core product with flavor options selected by the institution, the faculty or the learner, dependent on institutional model, in an easy-to-use format. (This analogy ignores the recent food contamination issues, though in some cases that might actually be an appropriate analogy in and of itself.)

What Can You Do to Help

Standards, standards, standards. Though Caliper, an open standard for measuring learning activity through IMS Global, was released a year and a half ago, there has been limited adoption, most of which can be attributed to the chicken or egg scenario. Those of us who work at higher education institutions need to be the incubators. We need to stand collectively together and, with loud and insistent voices, demand that learning resource vendors and tool providers adhere to more complex standards. We need to ask the same thing of our LMSs. We need to collectively spend our money to make that happen. RFPs need to require adherence to open standards, and the most recent versions of those standards. With purchasing power we can accelerate the development of interoperability.

This interoperability is the critical piece of the NGDLE puzzle.  But each institution, depending upon their models for online education, need to evaluate both LMSs and extensible products based on their particular needs and culture. Adoption depends upon culture.

Our options are to either evolve what we have or continue to wait on a future that has not materialized in the years since it was conceptualized. And we can evolve, intentionally, now. An evolution, without the blood of a revolution, can have revolutionary effects for learners.  Let’s put our money on that.


Author headshot


Sasha Thackaberry, Ph.D.
Assistant VP, Academic Technology and New Course Models
College of Online and Continuing Education
Southern New Hampshire University




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Ask Congress to Address the Housing Allowance for Online Veterans in New GI Bill

Veterans taking all their college courses online are getting short-changed. As Congress moves to rework the GI Bill, let’s get them to fix this problem.

We need your help. Read the background and see how to respond at the end.

The GI Bill Reduces the Housing Allowance for Fully Online Students

Veterans of the U.S. armed services are eligible for funding to pay for tuition, fees, books and supplies, and a Basic Allowance for Housing (BAH) while pursuing postsecondary education. However, if the veteran takes of his or her courses at a distance, the BAH is greatly reduced:

“The GI Bill is available for independent, distance, or Internet training. This type of training is usually offered by institutions of higher learning and similar rules and rates apply. (Note: If you are utilizing your Post-9/11 GI Bill benefits while taking ONLY distance-learning courses you will be paid a housing allowance based on 50 percent of the national average payable in the United States.)” 

Yes, they receive HALF the amount they would if they attended on-campus courses.

Photo of Danny Stuckey

Veteran Danny Stuckey received half of his housing allowance because he took all of his courses online

Examining the GI Bill payment rate for the academic year beginning August 1, 2017, that is a reduction of $804.50 per month. That’s a significant amount of money.

I’ve heard stories of veterans taking one class face-to-face (perhaps even a one-hour physical education course) to remain eligible for the full amount. As Pat James of California Community Colleges’ Online Education Initiative commented to me about this practice, “they burn their benefits on useless courses.”

So Why Care Now? Congress is Updating the GI Bill’s Educational Benefits

In a headline story from last Friday, Politico reported:

“Congressional Republicans and Democrats are moving ahead on a plan to expand educational benefits for veterans under the Post 9/11 GI Bill. The bipartisan legislation unveiled on Thursday is expected to move quickly, at least through the House, over the next several weeks.”

While we appreciate the several advances being proposed (Military Times calls them “beefed up” benefits), the current version of HR 3218 does not fix this problem with the BAH reduction. In fact, it doubles down on it by including a similar provision (on page 31) in a section defining a new “Department of Veterans Affairs High Technology Pilot Program.” A similar reduction of 50% of the “Housing Stipend” is proposed for distance learning programs participating in that pilot program.

Let’s Hear from a Veteran Who Experienced the Problem

We put out a call for veterans to share their experiences with this rule. We are seeking more stories and will continue to share them. Let’s start with just one veteran, Danny Stuckey, who served seven years in the Marine Reserves, four years of active duty in the Army, and three years in the California National Guard. After a break from service, he has served in the Army Reserves since 2013.

What impact has the BAH rule had on you?

“When I first tried to use the Post-9/11 GI Bill I had to stop pursuing my degree at Liberty University with the GI Bill and tried for an education degree through Grossmont College. I was later able to switch to Point Loma Nazarene University where I changed my major but used other funds to complete my BS in religion at Liberty University.”

“With a busy work schedule I was looking to finish my BS degree online using the Post-9/11 GI bill. I live in San Diego, California yet I was taking classes online at Liberty University in Lynchburg, Virginia. I had to pay for my education in other ways. I felt this was an unnecessary burden put on veterans to qualify for the full amount of benefits.”

Have you made changes in your plans, such as enrolling in extra courses, because of this rule?

“Yes, I wanted to take all online classes so that I could do my school work early in the morning when I had the time and was mentally alert to work on it (I am a morning person). I then had to take night classes to fit with my full time work schedule which made it difficult to focus on school work.”

“Before I completed my degree I switch to a school in San Diego so that I could qualify for the full amount of the GI Bill. I was attending Grossmont College and had to take a night class that meet twice a week in order to qualify for the full amount. This was a difficult balance as I was working full time, had a full time load of classes, was married with four children, I ran an addiction recovery group one night a week, and I was a home fellowship Pastor another night a week.”

What’s your recommendation for ensuring this rule works for our Veterans?

“I would suggest having the same rule for resident courses as online courses as long as the online courses are accredited the same as resident courses.”

What else would you like to say about how this rule has impacted you and your family?

“Looking back I would have waited to use the GI Bill at a more opportune time as going to night school and fulfilling all of my other life obligation19944622_10155543940588566_6946547364830189001_os put a lot of strain on my marriage, my family, and my children. It was not worth the BAH.”

If you have additional stories, send them to Lindsey Downs of WCET and she can send you a list of questions that we are asking. We plan to use them to demonstrate the problems encountered by student/veterans. If you would like to share your story, but keep your anonymity, we will honor your request.

How Can You Help? Contact Your Representative and Senator

If you would like to see this rule changed, contact your local member of the House of Representative and U.S. Senators. Although if you are going to do only one, start with your House member, especially if he or she is a member of the House Veterans Affairs Committee They are probably tired of hearing about health care anyway.

It would be helpful if you could get leadership from your institution to issue an official letter. Please do not respond on behalf of your institution or organization unless you have the proper local approval. Alternatively, you can respond as a private citizen. You can mention your job title, that you are a student, or that you were a student. Just be clear that you are providing your own opinion and not that of an institution or organization.

In addressing your letter, you might find this guide to address and salutations very handy. Here is a sample letter, but be sure to tell your own story or the stories of your student/veterans:

= = = = = = = = = =

The Honorable (Name)
U.S. House of Representatives
Washington, D.C.  20515

Dear Representative (Name):

Veterans play a tremendous role in making the country what it is today. I am pleased to see that, beginning with HR 3218, both the House and the Senate are implementing needed improvements and expansions to the educational benefits that veterans enjoy through the Post-911 GI Bill.

More can be done to improve benefits for veterans who chose to pursue their degrees or certificates through distance education. According to the Digital Learning Compass ( analysis of U.S. Department of Education data, about one-in-seven students now pursues their degrees fully online and that number has grown for several years in a row.

Unfortunately, the U.S. Department of Veterans Affairs’ rules have not kept pace. According to their website ( describing housing Basic Allowance for Housing benefits for “Independent and Distance Learning Training”:

“Note: If you are utilizing your Post-9/11 GI Bill benefits while taking ONLY distance-learning courses you will be paid a housing allowance based on 50 percent of the national average payable in the United States.”

I strongly object to this reduction in benefits for no apparent reason. A veteran may attend classes on-campus one semester and receive full benefits. If she takes all her classes from her house from the same institution the next semester, her benefits are halved. Some veterans have circumvented this rule by taking one one-credit course on campus so that they can qualify for the benefit.  <<>>

As long as the institution meets all other eligibility criteria, how the student studies should not have an impact on veterans’ housing allowance benefits. With the possible exception of a small bit of commuting, all of their other costs remain the same. As you are reconsidering the GI Bill;s educational benefits for veteran’s, let’s bring them into the 21st century.

Thank you,


= = = = = = = = =

House of Representative members by state:


Thank you,

Russ & LindseyRuss Poulin

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

Photo of Lindsey DownsLindsey Downs
Manager, Communications
WCET – WICHE Cooperative for Educational Technologies



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We Need YOU! …to comment on Federal State Authorization Regulations

The Department of Education seeks comments about higher education regulations that may be “appropriate for repeal, replacement, or modification.” WCET and the WCET State Authorization Network (SAN) will comment about the federal state authorization regulations that are scheduled to be effective on July 1, 2018.

In recent months, we have seen several federal higher education regulations become sidelined through delays and reviews by the Department of Education as described in Russ’s blog post from last week,  “Federal Regulations: Delays, Reviews, and a Call for Comments.

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It is time to make your voice heard.

You may wish to review our comment themes, concern about misstatements, and the process for you to submit comments below. We hope you will submit comments by the August 21, 2017 deadline. Volume matters!

Two Themes for Our Comments to The Department

Removing the Federal Regulation Has No Impact on State Regulations

First, we will advise that elimination of federal state authorization regulations WILL NOT ELIMINATE state regulations for institutions to complete any state-mandated compliance requirements in states where students are enrolled or receive services from the institution. We support the intent of the federal regulation to provide additional consumer protection for students by requiring that the institutions follow state laws where they serve students if they wish to participate in Title IV funding. We maintain that proof of state authorization provides transparency. Additionally, we maintain that providing notifications and disclosures eliminates ambiguity. We will raise the point that not only do these regulations protect the student as a consumer, but also compliance with these regulations protects the institution from possible violations of federal regulations such as Misrepresentation per 34 CFR 668.81-668-75 or a similar state-based rule. Simplification of the regulation is possible, but elimination leaves students less protected.

If the Department Retains the Regulation, Clarifications are Needed

Second, if the Department chooses to move forward with the regulations with no changes, we ask questions and seek clarification on several items that are unclear in the regulation’s wording or have become unclear due to subsequent actions. Question mark drawn on a chalkboardWe don’t want to see a repeat of the 11th hour enforcement delays witnessed over the last few weeks and we want to make sure that institutions are following the most current expectations.

The clarifications include the following:

  • Will the Department enforce all or part of the regulation on July 1, 2018?
  • Clarification on state of compliance location? Use of the word “reside” is inconsistent with state laws.
  • Definition clarification of state authorization reciprocity agreement.
  • Complaint Process/Authorization in California where there is no complaint process for out of state public or non-profit institutions.
  • Definition of Solely Distance Education – what about hybrid programs?
  • Disclosures and written acknowledgments.
    • Public Disclosures – regarding Adverse Actions.
    • Individualized Disclosures – regarding the definition of “prospective” student and desired form of acknowledgements.

Watch for Myths about the Federal Regulation Elimination

Myth 1—Eliminating the Federal Regulation Makes State Authorization Go Away:

A classic example of a misunderstanding of the states’ role was reported by The Chronicle of Higher Education, in their breaking news articles under the headline The Ticker. Per the recent request by the Department for comments, an anonymous commenter from Maryland indicated supporting the rescission of “State authorization rules” because the state authorization rules require a significant amount of time and money signing agreements, and coordinating with each state, and monitoring the location of the students. The commenter also referenced offering a teacher preparation program.

Reality 1:

The Department released the Final Rule on State Authorization of Postsecondary Distance Education, Foreign Locations in December 2016. The essence of the regulation is that to participate in Title IV financial aid funding, the institution must be compliant in the states that the institution enrolls or provides services as REQUIRED BY THE STATE. States have had these regulations on their books long before the Department of Education decided to add it in 2010 and they will remain regardless of what actions the Department takes.

Dear commenter from Maryland,

NONE of those tasks will go away with the elimination of the state authorization federal regulation. Has your institution considered applying to become a SARA institution to minimize the application workload and possibly the financial requirements for authorization by the state higher education agencies? Tracking your students is important to your institution for marketing and financial planning of the institution, accreditation review, and financial aid compliance as well as state authorization compliance management. Finally, you mention that you are offering a teacher preparation program. Are you aware of the prerequisites for licensure and certification in the states where your institution wishes to offer the teacher preparation program and do you have approval by those states’ licensure boards? Please consider joining the State Authorization Network (SAN) for further resources, training, networking, and support. Or just read our many pieces of advice for free.

 Best of Luck!

Cheryl, Russ, and your State Authorization Network friends

Myth 2 – States are Using State Authorization as a Revenue Generating Tool:

The Senate-sponsored 2015 report Recalibrating Regulation of Colleges and Universities: Report of the Task force on Federal Regulation of Higher Education indicated that state authorization requirements are a revenue generator in many states.

Reality 2:

Our work with state agencies has shown differently. In most states, we have noted modest fees for the agency providing oversight of the institution offering activity in the state. Fewer states have unreasonable requirements for travel to or from the state for reviews. Regardless, elimination of the state authorization federal regulation will not change the state compliance required costs for the institution. The institution will still be legally mandated to provide all compliance costs either directly to the individual states for compliance or through their fees to the SARA state portal agency and NC-SARA, if the institution is operating under SARA for compliance.

Institutions may minimize compliance costs due to fees and staff time by applying to become a SARA institution. The institution should do a cost benefit analysis to compare the costs of state and national SARA fees with the fees associated with the individual state’s authorization fees and staff time costs to manage individual state’s authorization requirements in the states the institution wishes to offer activities.

Process for Commenting

The Request for Comments was published in the Federal Register on June 22, 2017. The deadline to submit comments is August 21, 2017. confused looking man hodling a long list that reads Please be sure if you are providing the official comment for your institution that you receive proper approval at your institution. Your other option is to comment as an individual. If you choose to include your current position, please make it clear that you are commenting on your own.

The request requires that comments are to be submitted through the Federal eRulemaking Portal ( or via postal mail, commercial delivery, or hand delivery. The Department WILL NOT accept comments by fax or email. You must also include the DOCKET ID (ED-2017-OS-0074) at the top of your comments.

The Department indicates that they strongly encourage that comments be sent electronically, but the appropriate address for mail or delivery is as follows:

Hilary Malawer
400 Maryland Avenue SW., Room 6E231
Washington, DC  20202.

We strongly encourage your participation! This request for comments indicated no restrictions and simply asked for input on regulations that may be appropriate for repeal, replacement, or modification. WCET will probably be commenting on other issues. Watch for those updates in the future.

This is your time to be heard! Let’s do this together!

Cheryl Dowd


Cheryl Dowd
Director, State Authorization Network



Russ Poulin


Russ Poulin
Director, Policy and Analysis



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Federal Regulations: Delays, Reviews, and a Call for Comments

Federal higher education regulations are under fire and the Department of Education wants your input. Let’s give it to them.

Only the Teacher Prep regulations suffered the quick death of the Congressional Review Act. Several other postsecondary consumer protection regulations now face delayed enforcement and/or possible death by committee.

Street sign reading "Wrong Way Go Back".

Higher education regulations are being delayed and reviewed…and, perhaps, replaced.

Recent Department Actions on Delays and Reviews

After glancing at the calendar and noticing that July 1 was approaching, the U.S. Department of Education seemed to realize suddenly that several regulations that they did not like were about to reach their effective date. The actions they took to avoid the July 1 deadlines:

  • Gainful Employment (in short, institutions had to report on employment outcomes for graduates) – On June 14, the implementation of the regulation was delayed and it was announced that the rule would be subject to a new negotiated rulemaking committee later this year. On June 30, the Department delayed disclosure requirements by a year to July 1, 2018. Yesterday, the Department opened a shorter-than-usual 30-day comment period on this regulation.
  • Borrower Defense to Repayment (in short, rules regarding defrauding students taking out federal loans) – In the same announcement with Gainful Employment on June 14, this regulation was delayed and will be subject to a second negotiated rulemaking committee later this year.
  • Cash Management (in short, institutional disclosure to student about options in finance tools used to use and receive financial aid funds) – On July 3, the regulation’s disclosure requirements were delayed until January 1, 2018 pending the release of a new “final suggested disclosure format for student financial accounts.”

In the press release announcing the change of status for the first two regulations mentioned above, Secretary Betsy DeVos said:  “It’s time for a regulatory reset. It is the Department’s aim, and this Administration’s commitment, to protect students from predatory practices while also providing clear, fair and balanced rules for colleges and universities to follow.” Yes, you read that correctly, she said “fair and balanced.” At least she did not say “repeal and replace,” as that has not been going so well.

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.A Call for Comments on Regulations

In a separate action, the Department announced a commenting process “seeking input on regulations that may be appropriate for repeal, replacement, or modification.” Submit comments by August 21, 2017.

In addition to those comments, the Department presumably will rely on the 2015 analysis produced by the Senate Health, Education, Labor, and Pensions Committee: Recalibrating Regulation of Colleges and Universities: Report of the Task Force on Federal Regulation of Higher Education. The Report made several recommendations on improving regulatory processes and cited several regulations that needed they thought should be repealed or replaced, such as:  Verification of student eligibility for financial aid, return of Title IV funds, financial responsibility standards, institution accreditation, and state authorization for distance education programs.

What’s Should You Be Doing?

You should comment.

Pick Department of Education regulations that you like or don’t like and comment. Don’t not feel limited to those issues mentioned in the Senate’s Report. This may be a time to comment on some of the issues that we’ve mentioned in the past in which distance education or educational technlogies are treated differently. I have in mind regular and substantive interaction, reporting last day of attendance, and some student identity regulations.

If you comment officially for your institution or organization, be sure that you have all the necessary approvals so that you do not get into trouble. Alternatively, you can comment as an individual. If you do so, you may mention your current position, but need to be clear that you are commenting on your own.

Cheryl Dowd, WCET State Authorization Network Director, and I are working on the first letter that WCET plans to submit as part of this process. We will focus on state authorization for that letter. Watch the WCET Frontiers blog for highlights of some of the issues that we plan to raise in that letter. Spoiler alert: We disagree with the Senate report. Since states regulate institutions regardless of whether or not there is a federal regulation, we think it is appropriate for the Department to check whether an institution is authorized in a state in which it disburses federal financial aid.

Babies, Bathwater, and Brains

Finally, a comment on “babies and bathwater” is in order. Almost all these rules are about consumer (meaning student) protection. In the zeal to clean house, the Department may become overzealous in discarding needed protections along with regulations that it finds abhorrent.

Let’s hope that we will collectively use our brains about what will and will not work…and what is best for students.

We need to avoid political knee-jerk reactions that, for one side, are limited to only 140 characters , for the other side, can be expressed only in 140 pounds of regulations.Photo of Russ Poulin


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


Photo credit: Wrong Way

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