Creating an inclusive student environment at UNE Online

I believe that developing an inclusive and welcoming classroom environment is an important aspect of effective teaching and learning. But, how can we foster such an environment? Especially in an online classroom, where it may be harder to make connections between faculty and student?

Today we welcome Gregory Andrews, the Student Support Specialist at the University of New England’s (UNE) College of Graduate and Professional Studies. Greg will discuss UNE’s institutional philosophy for welcoming students to create an inclusive online environment.

Are you as equally inclusive in your classroom? What do you do to respect student identities in the online classroom environment?

Enjoy today’s post!

-Lindsey Downs

When looking for colleges, whether online or the more traditional brick and mortar, many students look at tangible areas. Questions often asked are: ‘How much will this cost?’ ‘How long is the program?’ ‘Are there residency requirements?’ ‘Is there a decent professor to student ratio?’ The list goes on and on.

One question that is rarely asked of an institution is ‘How will you make me feel like an individual?’ On top of this, nobody ever asks ‘How will you respect and work with my identities and create an inclusive environment?’ Whether social identities (religious, gender, race, etc.) or personal identities (parent, athlete, full time employee, etc.), these are often areas that a person must work with to create the best situation in a college environment, and rarely does a student question the institution unless it is a major issue.

The UNE Online Way

UNE Online however answers these questions before they are ever asked. You may be reading this and asking yourself how an online college program can possibly answer all of these questions regarding identities. The answer is simple; UNE Online listens to each student, and not only reactively but proactively.

Whether you’re a student in the Masters of Science in Education programs, Masters in Public Health, or even thgroup of students with various technology devicese Masters in Medical Education Leadership, you’re not given a voice; you’re simply encouraged to use the one you already have. Enrollment Specialists and Student Support Specialists are in contact with you from the moment you inquire about a program until the moment you graduate, and beyond if you like!

The inherent value of online education is the ability to work within the student’s schedule. Most people reflect on employment as the major reason why that is important, but consider this, UNE Online has students all over the world in different time zones, practicing different cultures.

Here at UNE Online, our staff creates opportunities to connect with each student to learn about their needs, and how to best make the connection between what they already know, and what our programs want to deliver!

Staff and Student Connections

You may be curious about the ways that we build connections between students and staff members.  We recognize that distance can be tough, so we are willing and able to utilize many different ways to stay connected. While e-mail and phone calls are the usual ways we stay in touch, our staff is always willing to go above and beyond. Skype or Google Hangout video chats are common, especially when we are reaching out to students in other countries.

In some cases, our students may not have the best connections or reception, and a simple instant message conversation might be in order.

We strive to keep students connected to the UNE community by checking in occasionally, and communicating ways that meets their technological needs!

The Platinum Rule

In the meantime, our support staff initiates“New Student Conversations” with every single newly enrolled student. word cloud or word jumble with the words golden, rule, and platinum. Platinum is in the middle in larger letters

The purpose of these calls is to get to know each student. The Student Support Specialists are looking to learn more about each person, from background, to goals for the future.

It is in these conversations that the UNE Online staff seeks to live by the “Platinum Rule” of Social Justice and Diversity, “Do unto others, as they would have done unto themselves.” Basically, the Student Support Specialists strive to create a connection and an inclusive environment that ensures every student has a chance to be themselves. They become a name, a person, a backstory, and a future graduate. Our students are never just a number.


When you’re a student with a UNE Online program, you are a person, and you are every bit as accepted as a person as you were when we called you to congratulate you on your entrance into your program.

So when we say “Welcome” at UNE Online, we mean it in a way that is very holistic and inclusive. If you’re currently a student with a UNE Online program, let me once again say, “Welcome.”

If you’re not a student with UNE Online, we welcome you to consider us, where acceptance is more than a letter, it’s an educational experience.

Greg Andrews headshot

Gregory Andrews
Student Support Specialist
University of New England’s
College of Graduate & Professional Studies

This post was originally published on the UNE Online Vision Blog.
Photo of Greg courtesy of Revolution Summer Photography

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Mission Accomplished: St. Leo’s New Ecosystem Transforms Learning

You’ve heard of course management tools, you’ve heard of ePortfolios… but you’ve never heard of this!

This week we welcome Dr. Jeff Borden, the Chief Innovation Officer at Saint Leo University, to discuss the implementation of a new and exciting learning ecosystem. That’s right, an entire system with one goal: an infrastructure to transform learning for students. Read on to learn about the Lion SHARE system and the implementation strategies involved.  We’re thrilled to learn about this platform as the journey continues!

Lindsey Downs

Do you remember when then-President George W. Bush stood on that aircraft carrier with the banner strung behind him stating, “Mission Accomplished?”

While the banner was created by the crew of the ship which was returning from deployment, the world saw it as our leader stating that we had beaten terrorism. The speech (and pictures) became quite controversial with many asking if any kind of proclamation of that magnitude was appropriate, etc.

Today, I make just as controversial a statement. On January 9, 2017, Saint Leo University transformed learning.

Oh My, Is this Another EdTech Fad?

I know that you know just how controversial this is. After all, people have been ringing the bell of disruption and transformation for decades. MOOCs will change everything, adaptive platforms will finally fix education, connectivism is the answer, etc. Heck, I remember being in high school when “Base 8” was unleashed on my younger sister. It was going to “fix” our country’s problem with math. Sigh.

But more than the obvious generic cynicism, I know this statement to be specifically controversial. I know this because on multiple occasions I or one of my staff have explained what we built to others and they have actually (although politely) called us liars. Their experience is usually cognizant of how detrimental politics is to education (despite its ubiquity), so people simply do not believe we could do in under 18 months what we in fact did. So what did we do?the Lions SHARE logo

Simply – we built an infrastructure that will transform learning for students, at scale. Lions SHARE is the infrastructure for a new paradigm regarding learning which includes a social, course, ePortfolio, synchronous, and productivity toolset. It supports best practices in andragogy, ed tech, neuroscience, assessment, and curriculum management. We’ve built a multi-tool system acting as one which white-labels every tool so that users will not need to know brands and can call our support team to get help with the entire system from a single communication point.

We’ve built a learning ecosystem.

What Exactly is this Learning Ecosystem You Assembled?

Yep, that message is packed with buzz words and fortified with ambiguity! So let me deconstruct it just a bit.

Our learning ecosystem – a word I use intentionally because of the notion of interdependence between parts – is now whole. While we still have a few integrations left to do, students will see ONE system vs. the five user-facing and nine back-end commercial tools in play. Faculty will see a system that introduces legitimate artificial intelligence (AI) to help create better learning experiences and drive efficiencies. Saint Leo as an organization now has an infrastructure that allows any learning variable to be contrasted, compared, or correlated to any other learning variable throughout the entire system.

But How Did You Succeed Where So Many Others Have Failed?

But, to those who are still coming back to the idea of, “too good to be true,” let me see if I can quell what I assume are natural arguments.

Users (aka faculty and students) won’t use it.

It’s easier to inoculate against a bad practice when you know it’s coming. In my time, I’ve likely seen 1,000+ strategies and initiatives fall flat because of poor adoption. In some cases, the “duck-n-cover” approach that many faculty use was employed. Being intelligent people, faculty watch as the initiative-du-jour is touted term after term or year after year, only to be completely absent within 12 months, as the next “big idea” takes center stage. Likewise, is the poor assumption that faculty are somehow different from everyone else when it comes to technology adoption.

Does higher education employ luddites? Sure. Does banking, insurance, and health care? Yep. But most faculty are reasonable. In other words, if you put a solution in front of them that actually makes their lives better, easier, etc., they will adopt it. If the pain of adoption isn’t too hard and / or the solution itself doesn’t create new problems that are worse than the original, reasonable people will adopt it.


Screen shot from the LIONS Share platform

The difference between a professor and the rest of the population isn’t their aversion to risk, it’s their ability to argue against poor solutions. My college-administration father always says, “Faculty put the critic in critical thinking.” They can wield an argument like a surgeon’s scalpel, so you had better be sure a solution is actually a solution before putting in front of the professoriate.

Faculty and students won’t use what they don’t have to use. 

I’m not sure if this is as true as it used to be, but there is likely some merit to this. So, taking a page from Steve Jobs (who knew the iPod wouldn’t be nearly as powerful or popular as a phone that leveraged iPod capabilities) we created Lions SHARE to be used. Yes, we will require usage for simple things like a syllabus, entering official grades, and deployment of end-of-course surveys, but it will take more than that.

One such example is our Artificial Intelligence strategy.  If you give faculty and students the ability to do something they couldn’t do without your solution, reasonable people will adopt it! So, let’s take the conundrum of groups. Faculty (generally speaking) hate using groups. There are a myriad of reasons, from grading an individual for someone else’s performance to problems with group cohesion leading to hatred of groups by students, and beyond. But I think it is fair to say that groups are not used very often, nor very effectively in education.

But what if we could help solve one issue (at a time) through Lions SHARE?

Screen shot from lions share platform

Screen shot from the Lions SHARE platform

What if we had a “smart group” builder?  What if professors could say they wanted to ensure each group had a leader in it? What if they could group students by those who typically finish group work early vs. last minute so as not to frustrate students? What if they could pull indicators from other classes, social networks, personality inventories, and other tools to generate better groups from the start?  Now we’re talking about a system that will do things an individual cannot.  And that leads to more and more adoptions.

One system?  In 18 months?  No way.

We do hear that a lot.

But here are a few data points. First, we brought our partners (no, not commercial providers, but PARTNERS) to campus last year.

Note that we didn’t bring account managers – instead, we brought technologists. (Sorry account managers out there. I know you have a number to hit and everything…) We locked them in a room with plenty of caffeine and sugar and made them promise to give us a single system.

And for the most part, they bought in.  They agreed to help us.  How?  By giving up normally required tools for the greater good. Take profiles. Just about every technology system has one. But we don’t need 5 profiles for our users, we only need 1.


Screen shot from lions SHARE platform, profiles

They agreed to SHARE a profile from one of the tools, integrating it with all of the other platforms. Same for calendar. Same with helpdesk support – call one number for all tools and get help 24 hours a day. And imagine using a social networking tool for more than just profile based connections and more than just organizational / event subscriptions, but also connecting academic conversations into an activity feed. Now we’re talking. Branding and single sign on through ADFS was also helpful, but the partnership model is what really got us there.

But What about the People Involved?

I know, I know – I talked a ton of about technology here when the real magic is in the people. This is why we have a full-scale rollout of training for faculty, students, and staff. We have levels of training (Essentials, Savvy, and Sage) giving specific access to tools based on the training one has achieved.

As acumen grows, so will our ties to higher order learning theory and practice.

screen shot of lions share

Screen shot from the LIONS Share platform

We have completely redesigned our online courses to take advantage of both this system as well as what we know to be better practices with regard to learning. No more are we just trying to mimic bad practices from the face-to-face classroom in a digital fashion! We are leveraging the power of a digital world to craft better pedagogical / andragogical conditions, but that’s another blog.

And don’t forget the data. We’re betting on a bevy of better metrics than just grades or surveys. We will be able to show a student their growth as a learner over time, including how they learn best, and how TO learn best after they leave our school…

Find Out More…

If I haven’t convinced you, but have piqued your interest, I encourage you to continue to follow our progress. We have given our faculty the Essentials training. But like most people use less than 25% of their smart phone’s capability, we know the effective usage of our new system will require perpetual training and strategizing. And we are committed to doing just that.

Lions SHARE will transform learning.

Good luck and good learning!


Headshot of Dr. Jeff Borden


Dr. Jeff D Borden
Chief Innovation Officer
Saint Leo University




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Distance Ed Costs and Price: Not as Closely Correlated as You’d Think

What do you know about the price and cost of distance education? What do we charge students (the “price”)? How much does the institution spend to create the course (the “cost”)? In order to learn more about this issue, WCET conducted a survey with colleges and university leaders regarding the price and cost of distance courses.

Today we welcome Russ Poulin and Terri Taylor Straut to introduce the WCET Distance Education Price and Cost report. Today’s post will provide background on the survey and an overview of the results. Join us again soon for more in-depth discussions of results and Russ and Terri’s commentary on this important work.

Enjoy the read,

~Lindsey Downs

The long-held belief among legislators, governors, and other leaders is that distance courses should cost less to produce and deliver. Therefore, they assume that the price paid by students enrolled in these courses should be less than courses taught on campus.

WCET’s Steering Committee wanted more data about this issue. A committee (Joan Bouillon, Pearson; Tom Cavanaugh, University of Central Florida; Preston Davis, Northern Virginia Community College; and John Opper, Florida Virtual Campus) helped WCET staff identify the question for a survey of distance education professionals conducted last year.

Today, we release the results of that survey, additional interviews with higher education costing experts, and an in-depth report on the politics surrounding these issues in one state. As you will see in our concluding opinions, WCET’s Distance Education Price and Cost report is meant to provoke additional dialogue.

Distance Education Tuition is Usually the Same, but Fees Lead to a Higher Student Price

The reality at most institutions, according to the WCET survey, couldn’t be further from the truth with more than half (54.2%) of our respondents reporting that distance students pay more than on-campus students when tuition and fees are added. About three-quarters (75.1%) of institutions who completed the study indicated that tuition was the same, but the added fees continue to result in the price to students of distance courses being more.

Pink piggy bank with coins

The WCET report provides in-depth analysis of the issues of cost and price based on our survey and interviews with industry experts.

The analysis provides enough data and differing opinions to challenge the perspectives of just about anyone who reads it. It’s our belief that all parties involved in setting the price for distance education courses need a dose of the realities that the “others” are facing. This report provides those differing perspectives.

Relevant Definitions:

A common understanding of the terms used is essential. Survey respondents were given the following definitions in the introduction to the survey:

  • “Price” – This is the amount of money that is charged to a student for instruction. The components are tuition and fees. In the questions, we will be clear as to which “price” component (tuition, fees, or total price) is being queried.
  • “Cost” – This is the amount of money that is spent by the institution to create, offer, and support instruction.
  • “Distance Education” – When thinking of “distance education,” we favor the Babson Survey Research Group definition of 80% or more of the course being taught at a distance.

Distance Education Doesn’t Have to Cost More 

Our survey of distance education professionals asked detailed questions about the cost of twenty-one components in four categories (preparing, teaching, assessing students, and supporting faculty and students) of creating and delivering distance courses. Chart showing cost comparision of face to face and distance courses. 0% of face to face cost less, 57.1 % had no difference, 42.5% cost moreThe results reveal that for twelve (57.1%) of the components the respondents thought there was no difference in the costs. For nine (42.9%), of the components respondents thought that distance courses cost more and, in some cases, much more. Respondents did not identify a single component of a distance course at their institution that costs less.

 But, Does It Necessarily Have to Cost More?

Along with the survey of distance education professionals, we conducted interviews with higher education experts who have done extensive research and thinking on the higher education cost issue. Most of those experts who we interviewed challenged the status quo thinking that the cost of distance courses must be higher. They echoed an opinion that we heard from a few of the distance education professionals that many of the technologies and practices that began in distance courses are becoming ubiquitous across campus and the cost differences are lessening. In fact, some of them contend that when distance courses are designed from scratch, without trying to emulate the classroom model, they can be both more effective and cheaper.

It’s All about Mission

Historically, distance education’s mission has been to overcome the barriers of place or time. The mission was not to control costs. In fact, to reach some locations is costly. Distance education should not be held accountable to a mission it was never given.

The Price and Cost Debate is Getting Political

In recent years, governors and legislators have openly wondered about the price and cost equation. Decreased state funding has often been replaced by increases to tuition and fees. shadowed text art with word "political"Now that their constituents are complaining about affordability, they are asking uncomfortable questions. Meanwhile, distance education professionals are caught in a higher education economics ethos that shuns open examination of price and cost…and are expected to answer to a “controlling cost” mission that was not given them in the first place.

Russ Adkins, distance education expert and long-time friend of WCET, volunteered to add a chapter updating the actions over the last few years in his home state of Florida. The issues of cost and price have become very political there. The Florida Legislature created UF Online that is mandated to charge a price that is 25% lower than its on-campus counterparts. The Governor capped the distance education fees and threatened to eliminate them. A task force was created to examine distance education costs. Will other state’s follow suit?

Join the ConversationSeveral people in an office talking

The report presents different points of view both in the status of how things are and how they could be. There are sections that will encourage and annoy all readers.

Now it’s your turn.

Comment on this post. You can offer to write a post that outlines price and costs in your settings. WCET members should watch for a discussion item on these issues on Friday. Suggest other resources.

We will be talking about these issues throughout the year. Watch for more.



Headshot image of Terri
Terri Taylor Straut
Senior Research Analyst
State Authorization Network
WCET – WICHE Cooperative for Educational Technologies


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


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Words can be intimidating: Cybersecurity and Our Role in Higher Education

Today we welcome Mike Abbiatti, the executive direction of WCET and WICHE Vice President for Educational Technologies, to WCET Frontiers. Mike will discuss the term cybersecurity in higher education, why we should care about protecting privacy and data, and actions we can take to protect ourselves and our students from various data attacks.

Thank you Mike for bringing these important issues into the light!

Look for more from WCET in the upcoming months regarding privacy and data protection in higher education!

Enjoy this post,


The term “Cybersecurity” has multiple meanings and associated connotations throughout the Higher Education community. To the technical community, visions of hardware, software and specific technical skills take center stage. cybersecurity-wordle3In administration, Cybersecurity means enormous risks and costs associated with internal and external threats that impact students, faculty, staff, and donors. They must plan for the relatively new investments in cyber insurance and trained staff. To the faculty, cybersecurity means a specter that can be invoked by clicking on an unfamiliar (or seemingly familiar) link or attachment. Or by intentional sabotage by an unhappy employee or student. There is certainly more interpretation of the term Cybersecurity across our enterprise.

For the purpose of this blog post, I will dispatch with the term Cybersecurity and replace it with Privacy and Data Protection (PDP). After all, our community is in the business of providing access to curated content and credentials. We don’t prefer to delve into the infrastructure (that’s what IT folks do) and we aren’t impacted by the high level administrative issues……or are we? Is PDP so compartmentalized that we don’t need to worry about the topics addressed by IT and the institutional administration?

Why Should We Care about Privacy and Data Protection?

We are going great guns developing and distributing meaningful content all over the world! We are significantly responsible for bringing students of all ages, philosophies, localities, and backgrounds to the institution with every kind of technology known to man. The fact that technology moves from the home to the campus today is a great boon to technology-enhanced education, especially online delivery. So why should we care about Privacy and Data Protection?

Well, one needs only to do a few cursory (no pun intended) Google searches, or read some local news, one would see the risks that are inherent in what we do so well every day.  Our programs are clearly in the center of PDP because we present ourselves as a lucrative target for cyberthieves, and we are not spending much time or resources on protecting our information from would-be wrong-doers.

Figure in a hoodie sweatshirt standng in front of binary code (1s and 0s) over a world mapWe collectively assume that the role of technology is to enable higher education to lead the way into the future. Perhaps, the most unexpected and unregulated aspect of our progress is PDP. We are so proud of the mountain of data we collect on students, graduates, faculty, staff, donors, and potential donors, etc., we have overlooked the importance of having well thought-out and supported strategies that help us manage what we see today. We thereby have a much better chance of responding to challenges in the future. We would not expect less of our medical care, banking system or travel/transportation systems.

We are experiencing expensive ransomeware attacks, Denial of Service outages, theft of intellectual capital and attacks aimed at unsuspecting staff and students resulting in identity theft and all manner of undefined problems that seem to be on the increase in Education. It appears that the bad guys have the high ground at this point in history. The very open and trusting nature of our world has resulted in Higher Education being labeled as a Soft Target by law enforcement and the bad guys/girls.

Strategy and Actions to Protect Ourselves

Our current inability to protect our important information from bad actors can be mitigated by a clear Cybersecurity (or PDP) Strategy composed of three areas of responsibility operating together with a common vision.

First, we must accept the fact that our individual responsibility for protecting information is the foundation for success. We must educate ourselves about what to do, and what not to do to thwart and report both internal and external cyberthreats. The external hacker is not as dangerous as the internal employee threat. A sign on a fence that states to keep out its private property.Furthermore, the internal threat is characterized by unintentional actions on behalf of good-intentioned employee that expose personal and organizational data to external criminals. Long-term costs are very high and increasing.

Second, teams and operational units in higher education who design and carry out projects must accept the responsibility to protect critical data. We must reject the old mindset that IT is responsible for such things. In our world, we are bringing more new users of digital infrastructure than any other campus unit. In my humble opinion, our organizations should be raising the flag, and helping lead the way forward in being sure Privacy and Data Protection are front and center.

Third, our organizational leadership must accept the responsibility to provide the policy framework and resources required to make the Cybersecurity Strategy successful. Financial and political (policy) support for an effective PDP environment are critical.

Ask These Questions. Take Some Action.

In summary, Privacy and Data Protection in technology-enhanced education, particularly online education, is a real challenge with real consequences for failing to recognize the threat(s).

I will leave you with two interesting questions:

  1. What is the cost of a data theft event in higher education? Remember, the cost is not totally measured in dollars.
  2. Secondly, who is responsible for PDP Strategy on your campus?

If you will take the time to answer these questions, then I predict your viewpoint on working with IT, and administrators to be sure each level of responsibility is active will change.

Technology-enhanced education is both a blessing and a curse. Let’s empower ourselves and our students to benefit from the blessing and minimize the curse. It takes the entire institutional team to accomplish this complex mission. The WCET membership represent the tip of the sword in this ongoing battle.



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Mike Abbiatti
Executive Director, WICHE Cooperative for Educational Technologies
WICHE Vice President for Educational Technologies



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System(s) for CBE Readiness: Enabling Student Affordability and Success

Competency Based Education allows students to advance toward a completion goal based on their mastery of a skill or competency at their own pace. Establishing a CBE program can seem like a daunting task,  but, luckily, this post contains some help!

This week on WCET Frontiers we have a wonderful post from Carlos Rivers. Carlos brings ideas and inspiration for an institution looking to start a CBE program, based on experiences with developing a CBE framework at Texas A&M University-Commerce.

Thank you Carlos for the resources and advice on CBE program development.

Enjoy the read,


This post compiles institutional knowledge about CBE from key stakeholders at Texas A&M University-Commerce, including the Vice President for Student Access and Success (Dr. Mary Hendrix), Texas Affordable Baccalaureate program staff, Registrars, Financial Aid Office, and our Institutional Research Division. This guided article would not have been possible without their expertise and collaboration.

Are you CBE Ready?

That was the first question I asked attendees this past October at the Texas Affordable Baccalaureate (TAB) Intensive. Co-hosted by the Institute for Competency-Based Education (ICBE) and the Texas Higher Education Coordinating Board (THECB), the Intensive was a one-day event that included sessions on planning and implementing Competency-Based Education programs in higher education.

Attendees primarily were Texas institutions seeking TAB Grant Program funds to develop their own CBE programs throughout the state. While there was a lot of enthusiasm from attendees, figure one clearly shows that a majority (70%) of them clearly do not think their “back-end” business systems are ready to deliver CBE. The road will not be easy, but institutions that are selected in this statewide expansion of TAB degree programs can achieve significant cost savings for students and an analysis of the data after three years into the program indicate the potential to improve efficiencies for institutions.

This post focuses on the Inspiration & Investigation section of the new ICBE Development Framework for CBE programs, particularly on System(s) for CBE Readiness. Our hope is that this short guide from our experience at Texas A&M University-Commerce (TAMU-C) helps other institutions on their quest to adopt new educational models that have the potential to serve underrepresented pockets (often deep) of students.

Chart showing results from survey question

The TAB program at TAMU-C is the state’s first SACSCOC-approved competency-based baccalaureate degree offered by a public university in Texas. In 2012, there was not a lot of research on CBE out there, nor real efforts of collaboration amongst IHEs developing these types of programs. Needless to say, the planning & implementation stages felt much like the famous expression “building the plane while flying it.”

Fortunately for all of us there is now a plethora of resources on CBE to get you on the fast track to success. However, I will still warn you: when it comes to CBE, there is no one-size-fits-all approach. IHEs have begun to open up and share their own experiences, but I caution you to always be open to surprises and be ready to adapt, because what is true for one institution may not apply in your specific CBE model.

Include Every Academic and Operational Unit in Planning for CBE

Before discussing system(s) for CBE readiness, how many of you have already started to build your on-campus partnerships for a successful CBE implementation? Think about all the areas that implementing a new innovative program touches. Figure two shows examples of these important stakeholders. For example, the HR Director’s assistance was crucial to determine a faculty compensation model, and involving the Director of Testing was important to determine TSI requirements for these returning students.

My advice, which now in hindsight seems like a given: get key stakeholders involved early in the process, and let them have a voice. Remember, you are going to be asking folks who have probably been doing the same operations for the past decade, to adapt to a completely different model. Get them involved early, to avoid problems once your program is operational. Figure showing CBE Program Implementation

How We Addressed Our Systems and Business Process

Below is a guideline of each system and business process, and how we tackled each at TAMU-C:

Learning Management System (LMS): When this project started in 2012, we faced a big problem: our LMS was not intended to deliver CBE courses and competencies. LMS issues included the need for middleware that populate students in non-standard terms and also allow students to accelerate. A pre-test assessment was crucial to direct the student’s learning path to demonstrate proficiency. Your LMS selection needs to be able to adapt to the student’s individual learning needs. In essence, you have to start thinking about the SIS/LMS data integration task early. While some institutions decide to build their LMS in-house for CBE models, this route for traditional institutions can end up being quite costly; besides, most LMS vendors have or have plans to update their existing product roadmap to include a CBE friendly environment. Other institutions have decided to have two separate systems, one for CBE and another for traditional modalities. At TAMU-C we decided on one LMS for all of our programs, ensuring that our LMS vendor provides an entire ecosystem for learning, no matter the model. As you decide on your LMS selection for CBE, also consider that there are plenty of smaller LMS vendors that are eager to test the waters; seeking partnerships might allow you to reduce your overall costs.

Customer Relationship Management System (CRM): During summer, I attended the Noel Levitz National Conference on Student Recruitment, Marketing, and Retention. In more than one session I heard, “If you do not have a CRM, what are you waiting for?” Currently, the TAB program staff tracks contact and interactions in a spreadsheet, as you can imagine, this is an intensive manual process. At TAMU-C we recently have opted for Salesforce, which will allow us to capture faculty-learner interactions in a consistent format ideal for both analytics and reporting. It is crucial to start thinking how you will develop your engagement metrics for your program.

Student Information System (SIS): Our CBE model is based on 7-week term parameters; essentially, there are two TAB Terms within the traditional semester structure. Unfortunately for us, our SIS centers on standard terms. We had to create part-of-term codes within our standard term code structures in order to differentiate student enrollment metrics from one TAB term to the next. Most SIS (including yours, I suspect) focus largely on standard terms. I caution you that the workaround to adapt current systems is massively labor intensive, but not impossible. Some of the issues we have faced with non-standard terms include: state reporting for funding, tracking of census dates, drops for non-payment and payment plans, and tracking of veteran and military service members benefits.

Financial Aid: Issues related to financial aid arose from our SIS focusing on standard terms. Our CBE model requires not only 7-week parameters but also the ability to allow students to accelerate. All aspects of financial aid became an intensive manual process with spreadsheets, since Satisfactory Academic Progress (SAP) must be tracked for each individual student. A perfect example is the challenge of awarding Incompletes:

“A full-time TAB student has to enroll in 6 SCHs for financial aid to disburse. Let’s say the student masters the competencies and completes his/her courses successfully before the end of the TAB Term. Now the student has the option to accelerate by taking an additional course for the same flat rate, reducing their overall cost per course for the term. If the student completes the course, great, but what happens if the student doesn’t complete this third course by the end of the term? This student would be awarded an incomplete, despite having successfully completing two courses in their required full-time load. This incomplete would not allow SAP to be calculated, resulting in the loss of financial aid funds to the student for the next term, even though he/she accelerated.”

Point being, you have to be careful when awarding Incompletes to accelerators on financial aid. It is important to mention that there is a growing need for financial aid solutions/providers to support non-standard term models, or, together, we must request to our current SIS providers to update their systems to award financial aid correctly to meet CBE requirements.

Data Analytics/Predictive Analytics: The word analytics may sound daunting, but it is a very important piece to guarantee the validity of your program. When I came into this position in 2015, most metrics were being collected manually from program inception. What used to be a two to five-day process, turned into seconds from the push of a button, after automating key metrics. I would recommend finding a Business Intelligence (BI) tool that meets your needs or leverage current tools on your campus. However, you need to make sure you have the right talent to turn raw data into a competitive advantage for your institution. In our case, we partnered with our IR team to build CBE specific metrics.

Also, as important, be sure to embed continuous improvement processes in your metrics. For example: ICBE keeps running averages of each CBE metric since program inception, and we use the averages as benchmarks to analyze current term performance. Another growing field in higher education — and I saw a lot of use-case scenarios at the EDUCAUSE Annual Conference — is the use of predictive analytics to better understand student populations. While business intelligence has been used to understand what has happened and improve strategic planning moving forward, predictive analytics allows you to see what is happening now, so you can act on that knowledge today, when it matters. The use case scenarios ranged from making intervention programs on target populations to graduation/retention initiatives that have the potential to enable student success at all our institutions.

Transcription: A survey by the Technical Interoperability Pilot (TIP) project indicated that 42% of C-BEN institutions are issuing “dual transcripts.” The first transcript contains the traditional credit hour grade measures, while the other includes CBE mastery-based achievement designations. At our institution, students must attain an 80% or better on a post-assessment and/or project to pass the course. Faculty post a grade of A, B or F that is then converted to our traditional numeric GPA scaling system for transcription. Why did we take this route? We wanted to make sure our TAB students’ transcripts look identical to those of their peers in traditional degree programs to guarantee transferability and/or ease of application to graduate programs. Because we also understood the importance of providing evidence of learning to employers, we also use an e-portfolio to document proficiency.

Staffing: The TAB program at our institution is led by a program director with an administrative assistant who helps with daily operations. Two, professional-track faculty positions also teach in the program and provide orientation sessions to new students. The program uses existing faculty, university staff who meet SACSCOC credentialing requirements, and a few adjunct faculty who are paid an overload of $250 per student enrolled. Enrollment is capped at 35 students per course.

I leave the success coach for last, because this role has proven to be one of the most important roles to consider. This individual is there to motivate/assist students to move through the program. Current students and graduates of the program have expressed over and over how this individual has helped them move through the program to completion. You must figure out how a CBE model will affect faculty roles and loads/compensation, and discuss what additional staffing needs may arise with these new education models.

Recommended Tools: This post would not be complete without a couple of tools to help you along your CBE journey. The CBE Design planner by C-BEN helps institutions in creating high-quality CBE programs with access to a range of resource to get you on your way. The NCHEMS free CBE Cost Modeling Tool allows you to estimate CBE-related cost and revenues. NCHEMS provides both a blank worksheet and a sample to get you started!

We Plan to Expand and We Welcome Your Questions

This is a brief overview of what TAMU-C faced in its quest to implement our first CBE program. Currently, we are hoping to get two more CBE degrees on their way at our institution. We hope this short guide serves you in the development of your own program.

At the ICBE we strive for collaboration and the sharing of resources to avoid duplications of efforts, and to enhance best practices in CBE. We encourage readers to reach out to the ICBE to build partnerships, collaborate in research, and/or answer any follow-up questions you may have. For more information, please feel free to reach out to me at

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Carlos Rivers, MBA
Operations Research Analyst
Institute for Competency-Based Education
Texas A&M University-Commerce

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Providing Online Faculty with Support Services Can Make the Difference

What is the attitude toward online teaching on your campus? What has it been historically? Today on WCET Frontiers we are thrilled to have guest authors from Wiley Education Services, blogging about an interview with two members of their faculty fellows program. These distinguished faculty share their background with teaching online, attitudes toward online teaching, thoughts on working with instructional designers, and advice for fellow instructors just starting out with online classes. Make sure to check out the resources suggested by the faculty and the post authors!

Thank you and enjoy the read!

-Lindsey Downs

Online Learning: the New Norm

Online learning has become the new norm for universities and colleges. However, faculty attitudes around teaching online can vary significantly, with some faculty showing great interest in making the transition to the online teaching modality and others feeling more skeptical.

We spoke with two members of the Wiley Faculty Fellows initiative, a select group of distinguished faculty from the network of Wiley Education Services’ partner universities, about their own experiences teaching in the online classroom. The Faculty Fellows group is focused on innovative teaching and learning and has helped advance new pedagogical and technological approaches at their own institutions. In speaking with them, our goal was to understand what factors and circumstances played a role in their enthusiasm for online education so that other higher education administrators can foster a similar environment for their faculty, thus increasing the overall success of their online learning offerings.

Q: Give us some background on yourself and your history with online learning.

Dr. Polly Smith: I am the Associate Provost for Online Learning at Utica College, managing 22 fully online programs. I have 12 years of online teaching experience. I teach a variety of sociology classes online and previously directed a master’s of liberal studies online.

Dr. Ray Klump: I am a professor and chair of computer and mathematical sciences at Lewis University. I have taught at Lewis since 2001.

I began teaching in a hybrid format to supplement my face-to-face classes with online enhancements, but I officially started teaching online in 2009. That’s when I had the opportunity to work with a Wiley Education Services’ instructional designer and a team that would provide guidance on the tools I should use online, how to transition course curriculum for online consumption, how to set learning outcomes, and how to measure them more effectively.chalk board with words in chalk including online, degree, education, course, academics

Attitudes Toward Teaching Online

Q: You both have a long history with online education. What was your attitude when you first started teaching online and what do you think of it now? What impacted those feelings?

Dr. Polly Smith: At first I was very skeptical. My background is in secondary education and I thought that a traditional on-ground classroom was the best and only way to present content, achieve learning outcomes, and reach my goals as a teacher. But when I was first asked to teach a course online, I agreed because I’m a believer in the fact that you can’t knock something until you try it.

I began teaching online believing that I could do exactly what I did in the on-ground classroom, but that didn’t work. What I know now that I wish I had known at the beginning is that online education is not the same as teaching in a traditional classroom. The objectives are the same, the outcomes should be the same, but the way you deliver content is completely different.

As part of this realization, I learned that having the support of an instructional designer, who knows more about the technology and the techniques that work better in the online space, is perfectly okay! I am the content expert, but the instructional designer is the expert in the technology, the best way to lead a discussion, the types of learning activities you can use, and the best ways to do group work in an online setting. By working with an instructional designer, I am able to deliver my own content and curriculum in the most effective ways online. My experience would be very different without this support.

Dr. Ray Klump: As a computer scientist, I embrace technology and therefore had no fears about teaching online. I am always looking for new techniques and tools to keep things fresh and exciting in the classroom.

Teaching online has brought me a better sense of organization, which also carries into my face-to-face classes. I understand how to organize and structure a course to ensure that students are on the same page with me, that they know what’s expected of them, and that they can better chart their progress toward the end goals.

I believe I now have a clearer vision because I was forced to create a very clear picture of where students would be going as they continued through the course, which isn’t something that I had thought of doing when I started out teaching – online or on-ground. College students sitting in a lose circle, all on a tablet or phone device.Teaching online in partnership with an instructional designer has helped me create a very clearly articulated course map. And that, perhaps, is the biggest benefit that I have received from teaching online.

Working with Course Designers

Q: So you both worked closely with instructional designers for online course design. What was it like working with someone else to design your courses?

Dr. Polly Smith: As someone with a PhD who takes their content very seriously and believes that they are the expert, adjusting to working with an instructional designer was a challenge because I believed I had my course objectives and content delivery all figured out. I thought I could work with the students and could easily communicate my curriculum in the online space without changing my approaches. But it doesn’t work that way because the online environment is very different!

Instructional designers help you develop measurable course and module learning objectives, and then aid in determining how to best communicate that content in the online space. Their job is to identify and combine what’s comfortable for the faculty member, which is likely content or delivery methods that are more common to the traditional classroom, and adapt that to the new online space. You will witness the payoff of working with an instructional designer when you see your students respond to these new techniques and technology.

Dr. Ray Klump: It is a great privilege to have the opportunity to work with an instructional designer because they provide the guidance for how best to convey the material. Although the instructional designer doesn’t know the material, they certainly do understand how to make things clear and can recommend the right technologies, tools, and approaches that can make difficult material comprehensible to students online. This is helpful because, as a subject matter expert, I might not necessarily know where I’m being less clear or where students might need additional support.

An instructional designer is agnostic to the material, which means they are looking at it purely through the lens of a student who needs to understand. I think that’s very helpful. The instructional designer is there to provide guidance and to lend their very seasoned opinion on how best to convey the material and assess outcomes. And at a time when universities are being asked to focus more methodically on assessment than they used to because there is a lot external reporting that needs to be done, this collaboration is essential.

Q: Has what you have learned teaching and designing courses online informed your on-ground teaching?

Dr. Ray Klump: Teaching online has made me ten times the face-to-face instructor that I used to be, primarily due to the higher focus on organization and assessment. I used to believe that setting student learning outcomes, writing up the rubrics, and judging every assignment that came to you with a rubric would suck the joy out of teaching. But to be an effective online teacher, my instructional designer stressed that I needed to implement an organized assessment approach and I have found that has made me a much more effective instructor, both online and on-ground.

Words of Advice for Online Faculty

Q: All in all, what messages or words of advice would you share with a faculty member who is new to or highly skeptical of teaching online?

Dr. Polly Smith: If I were talking to a faculty member who was new to online teaching or still hesitant to try it, I would tell them to first take advantage of an instructional designer for support – that will save hours of frustration and improve the overall delivery of content online. They will help you communicate your ideas better in the online space, and that leads to far more satisfying instruction.

Next I would tell them that students want to interact with their instructor, they want to feel like they are important. When planning an online course, a professor needs to make sure that they have a plan for how they will communicate with students. Community in an online course does not automatically exist, but in my mind it is the key to the success of the online learning experience.

Implementing the support resources mentioned by Dr. Polly Smith and Ray Klump above for your institution’s online initiatives could help increase the effectiveness and satisfaction of your online faculty. For more online teaching tips, visit the Wiley Education Services’ blog.   

Dr. Polly Smith headshot, image of blond woman smiling in an academic conference room.
Dr. Polly Smith
Associate Provost for Online Learning, Professor
Utica College



Dr. Ray Klump headshot, image of man with glasses smiling in front of office bookcase
Dr. Ray Klump
Chair of Computer and Mathematical Sciences,
Professor Lewis University



Interview conducted and written by:

  • Carey Dempsey,  Senior Corporate Brand Manager, Wiley Education Services
  • Kelly Lewis-Pratl, Director of Market Strategy & Development, Wiley Education Services

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This interview has been edited for length and clarity.

Chalkboard Photo credit: Bluefied College

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Helping Students with Adaptive Learning: APLU and the University of Mississippi

This week we welcome Patricia O’Sullivan, Manager of the University of Mississippi Personalized Learning & Adaptive Teaching Opportunities (PLATO) Program to give us news from the APLU adaptive courseware grant front. Adaptive courseware can positively impact student outcomes and the research UM and the PLC team at APLU are conducting will have a huge impact on student success. We’re so excited to have Patricia describe the background and implementation of this program. The attitude of the different groups working together to help students is very inspiring!

~Lindsey Downs

Helping Students with Adaptive Learning: APLU and the University of Mississippi

Nearly a decade ago, the Bill and Melinda Gates Foundation (BMGF) made a commitment to support postsecondary success for low-income and first-generation college students. The BMGF seeks to remove barriers contributing to the education gap, including college readiness, affordability, and access. In 2014, The Foundation invested $20 million in The Next Generation Courseware Challenge. Educational technology companies selected for the challenge designed adaptive courseware to solve two problems in higher education: personalizing the learning experience for students in high-enrollment classes and scaling the personalized learning experience so it is available to thousands of students at the same time.

Research in the early stages of adaptive courseware adoption indicates that adaptive courseware used in blended courses (a mix of online and face-to-face) positively affects student outcomes. More research needs to be done, but adaptive courseware’s potential to make postsecondary education more accessible to low-income and first generation college students convinced the Gates Foundation to move forward with it.

BMGF Funds Adaptive Learning at Land-grant Universities

In 2015, the Gates Foundation awarded $4.6 million to the Association of Public and Land-grant Universities (APLU) to support a program called Accelerating Adoption of Adaptive Courseware at Public Research Universities. An APLU team, led by Dr. Meaghan Duff, Executive Director of the Personalized Learning Consortium (PLC) at the APLU, developed a grant opportunity to assist universities implementing adaptive courseware in courses with high drop, withdrawal, and failure rates. Of the eight university recipients of the APLU adaptive courseware grant, six are WCET institutional members, including my own institution, the University of Mississippi (UM).

Logo for the PLATO programAt UM, the APLU grant committee was spearheaded by Robert Cummings, Chair of the Department of Writing and Rhetoric, and included Chancellor Jeffrey Vitter, former Provost Morris Stocks, Interim Provost Noel Wilkin, Dean of Liberal Arts Lee Cohen, Assistant Dean of Liberal Arts Stephen Monroe, and Assistant Provost Tony Ammeter.  Upon being awarded the grant, UM established the Personalized Learning & Adaptive Teaching Opportunities (PLATO)  program to work with departments in the implementation of adaptive courseware. PLATO is housed in the College of Liberal Arts and supervised by Assistant Dean of Liberal Arts, Stephen Monroe.

Early Observations on Adaptive Learning at the University of Mississippi

With the grant goals in mind, UM will pilot six courses using adaptive courseware in 2017: college algebra, statistics, trigonometry, biology for non-majors, first-year writing, and chemical concepts.  We are in early days of the grant program, but I’d like to highlight three observations.

Instructor-rank Faculty are Key to Success. First, the majority of UM faculty currently participating in the grant are instructors, not tenure-track or tenured faculty. These instructors have asked important questions of the administration and of courseware suppliers to ensure the pilots run smoothly for students. They are developing courses, training to use the courseware, and engaging in communities of practice. Supporting our instructor-rank faculty is critical to the grant’s success.

General Education Faculty Eager to Personalize Learning. Second, University of Mississippi logoI’ve found UM’s general education faculty eager for solutions to the problems that prompted the grant: high failure rates and low student engagement in large, lecture classes. The task of teaching thousands of students each semester is immense, and personalizing the general education learning environment for students has been a challenge. By partnering with suppliers who participated in the Next Generation Courseware Challenge, departments are able to maximize the use of limited resources to bring personalized learning to our students.

Working Together, Universities Accomplish More. Finally, the APLU adaptive courseware grant has generated both formal and informal inter-university cooperation to effectively implement the courseware. The APLU has set up regular meetings between the eight universities so we can support each other and share resources. In addition, early adopters of adaptive learning at the University of Central Florida, Colorado Technical University, Arizona State University, University of Maryland University College, and American Public University System have been exceedingly generous of their time and expertise in helping those of us who are new to it. This kind of inter-university cooperation is not generated by excitement over the technology, although there is plenty of that sentiment among us. What stirs our passions is working together to create solutions for post-secondary students who want higher education, but face obstacles outside of the ‘traditional student’ model. The face of the typical college student is rapidly changing as is her experience of college. If higher education wants to continue to drive educational and economic progress, it is imperative to find solutions to educational barriers.

Adaptive Learning Focuses Us on Improving Student Success

Adaptive learning gives students a personalized learning experience tailored to their individual knowledge base. Using data from adaptive learning courseware, instructors are alerted to class-wide trouble spots in the curriculum, allowing them to target their instruction to those areas in which students need the most help. In addition, early on in the semester, well before the first high-stakes exam, instructors can see which students are falling behind, and intervene to keep students on track.

If we’ve learned anything from student support services, it is that lack of college readiness and financial struggles are key indicators for students failing classes and not completing their degree. If we can address college readiness through adaptive courseware, and work with publishers and EdTech suppliers to offer courseware at reasonable costs to students, we are on the right track.

At the heart of the APLU adaptive courseware grant is students, not technology. Although it has shown promise, adaptive courseware may not be a panacea for the problems of readiness, access, and affordability. Regardless, the grant has led those of us using adaptive courseware to form communities both on our campuses and across the nation to raise awareness of the education gap and to work for solutions to it.

Patricia O’Sullivan, Manager UM PLATO Program's photo


Patricia O’Sullivan,
Manager of the PLATO Program
University of Mississippi




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Education Department Confirms ‘Reciprocity’ Definition Clarification

Thank you Ted Mitchell!

In his last hours as the Under Secretary of Education, Mitchell wrote a letter to Marshall Hill (Executive Director, NC-SARA) and me confirming the clarifications to state authorization regulations that Department staff made to me and I recently reported. The Department has long-supported reciprocity as a path to state authorization for distance education. In response to a query from NC-SARA and WCET, today’s letter confirms a reciprocity definition that keeps one state from undermining the whole agreement.

U.S. Department of Education Under Secretary Ted Mitchell's official portrait

Under Secretary Ted Mitchell

If each state can do what it wants, there is no reciprocity. That was NOT the Department’s intent.

Conflicts Between a State and a Reciprocity Agreement Must Be Resolved

Suppose that a state’s laws or regulations are in conflict with a reciprocity agreement that the state is seeking to join or is already a member. The state and the agreement are expected to resolve that conflict:

“In other words, a distance education reciprocity agreement may require a State to meet the requirements and terms of that agreement in order for the State to participate in that agreement.”

The key sentences in Mitchell’s letter of January 19 describing the consequences of a state remaining in no longer being in good standing with a reciprocity agreement follow:

“Thus, if the Department becomes aware of an unresolved conflict between the terms of a reciprocity agreement and existing State statutes and regulations, affected institutions seeking authorization via a reciprocity agreement would not be considered authorized under the Department’s regulation. Once a State has resolved the conflict within its own body of law, or the reciprocity agreement amends its conditions so as not to preempt state law, affected institutions will be found in compliance. ”

Thank You and What’s Next

Marshall and I, are overjoyed at the clarification. I’m sure the more than 1,300 institutions participating in SARA are happy, as well.

The state authorization regulation might make it to being enacted in July 2018. We will learn more about Congress’s intentions after the inauguration. We also feel confident that the new administration will also be supportive of reciprocity. In any case, uncertainty about the future of the federal regulation remains, but states still expect you to be in compliance. Meanwhile, we are very pleased at the Department’s on-going support of reciprocity as a key part of the their regulation.

Thank you Ted. And thank you to the Department staff who worked very hard to craft this letter and deliver it to us this week.Photo of Russ Poulin


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

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Education Department Clarifies Its Intent on State Authorization Reciprocity

To paraphrase Mark Twain: “The report of SARA’s death was an exaggeration.”

Department of Education officials recently told me that they recognize the hard work over many years in creating interstate reciprocity agreements for state authorization. They also expressed surprise over the perceptions that their new state authorization regulations would harm reciprocity.

In a call initiated by the Department and a subsequent call to answer some follow-up questions, well-placed Department officials clarified widespread “misconceptions” advanced by me and many others. This blog post presents my interpretation of what was said in those calls. Due to these discussions, my view of the intent of the Department’s new reciprocity definition has changed.

The words This is welcome news. In Cheryl Dowd’s (the State Authorization Network director) and my initial take on the regulation and the subsequent reactions from several sources that we reported late last year, we all thought the regulation would end reciprocity. After all, if a state could do whatever it wants despite an agreement, what use is the agreement?

From what I heard in the calls, the Department intended the exact opposite. It continues its long-held support for reciprocity agreements as a way for institutions to demonstrate state authorization of distance education. Additionally, it recognizes the rights of states participating in the agreement to set the provisions for reciprocity and the decide what states may join.

A Brief History of the “Reciprocity” Definition

When the Department issued its proposed state authorization regulations earlier this year, they included a definition of a reciprocity agreement, saying that an agreement acceptable for demonstrating compliance with federal financial aid rules could not prohibit a state from enforcing its consumer protection laws. Several of those submitting official comments on the regulations (including us) requested this definition be clarified. After all, different people had different ideas as to what would count as a “consumer protection” law. The definition as proposed last summer:

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

Note that the Department talks only about the “concept” of reciprocity agreements as it is possible that subsets of states may decide to create multiple agreements. In this regulation, the Department is not addressing a specific agreement, such as SARA – the State Authorization Reciprocity Agreement. Even though SARA is the best-known reciprocity agreement for distance education. It counts 47 States (plus DC) as members and 1,300 participating institutions. In full disclosure, I was deeply involved in forming that agreement.

The final regulation (issued in December) included the following, expanded definition of an acceptable reciprocity agreement:

“An agreement between two or more States that authorizes an institution located and legally authorized in a State covered by the agreement to provide postsecondary education through distance education or correspondence courses to students residing in other States covered by the agreement and does not prohibit any State in the agreement from enforcing its own statutes and regulations, whether general or specifically directed at all or a subgroup of educational institutions.”

A text box reading: On page 16 of the final regulation, the Department made the following statement in responding to official requests gathered during the open comment period regarding the proposed definition of a reciprocity agreement:

“…we believe that if a State has laws that are specific to postsecondary institutions, the State’s laws should not be preempted by a reciprocity agreement that does not recognize those State laws. Thus, we believe that the definition of a State authorization reciprocity agreement should encompass a State’s statutes and the regulations interpreting those statutes, both general and specific, including those directed at all or a subset of educational institutions.”

Those of us outside the Department interpreted that language to mean that a state could enforce any of its regulations even if that enforcement conflicted with a reciprocity agreement it had joined. You can see how we came to that conclusion.

Based on my recent conversations with Department personnel, our interpretation was wrong.

Key Takeaways Regarding the Department’s Intent

What did they intend? The intent of the language in the final regulation was to assure that a reciprocity agreement could not supersede state laws not covered in the agreement. The language required some “threading the needle” between state and federal laws and some of the Department’s ultimate intent seemed to be lost in the final wording.

Let me interpret the Department’s intent in my own words based on our recent conversations. In brief, the Department considers a reciprocity agreement to be in compliance with their requirements as long as the state’s laws and regulations and the provisions of any reciprocity agreement the state joined are not in conflict.

These details were fleshed out a bit more in our conversations:

  1. The Department reaffirms its support for reciprocity agreements as a path for an institution to obtain authorization in another state.
  2. Reciprocity agreement member states jointly define the provisions of the agreement and decide upon membership in the agreement. If a state disagrees with those provisions, it does not have to join. State participation is voluntary.A text box reading:
  3. If a state decides to join a reciprocity agreement, how it regulates institutions covered by the agreement cannot conflict with the provisions of the agreement. As an example, suppose a reciprocity agreement treats all sectors of institutions the same and prohibits states from imposing state-specific tuition refund formulas on out-of-state institutions participating in that agreement. Member states must abide by those provisions or they are determined to be in conflict with the agreement. Reciprocity member states cannot unilaterally impose their own conditions on participating institutions, unless those conditions are outside the scope of the reciprocity agreement.
  4. Reciprocity agreements must have a process to resolve any conflicts between state regulations and actions and reciprocity agreement provisions. Department personnel further clarified that they would expect an agreement to:Text box reading: "If there is a conflict, it must be resolved or the state leave the agreement."
    • Have a process to reject applications from states that cannot or do not plan to abide by the agreement,
    • Have a mechanism to review and resolve conflicts between state regulations and reciprocity agreement provisions, and
    • Have the ability to dismiss member states that do not abide by reciprocity agreement provisions.
  5. The Department will investigate unresolved conflicts between a state and a reciprocity agreement. Among actions the Department could take:
    • Declare the conflicting state’s institutions ineligible to offer federal aid to distance education students in other states participating in the agreement until the conflict is resolved,
    • Declare the agreement is out-of-compliance with federal regulations if it does not have the have the proper mechanisms to resolve conflicts, or
    • Take any other action it deems appropriate.

The Bottom Line and Making this Official

Bottom line: This is great news for SARA and, more importantly, the countless students who are now protected by that agreement and had no protection just a few years ago.

Again, this blog post presents my interpretation of what Education Department leadership intended all along, but was hard to determine from the final regulation. A Department official suggested that we submit a request to the Department to officially clarify (perhaps through a “Dear Colleague” letter) the intent of the reciprocity agreement definition. WCET, the State Authorization Network, and SARA will, together, promptly draft an official request for clarification.

Meanwhile, this places me in an awkward position. The Department staff reached out to me to clarify their intent. They are completely aware that I will share my impressions publicly, but they asked that those participating in the calls not be named. You can draw your own conclusions, but I think it has much to do with the calendar.

Glad to See the Department Support Reciprocity

As a result of these conversations with Education Department leadership, my main objection to the recently released regulation has been mitigated. I still have some other, more minor, problems with the final regulation, but those details will be explored on another day.

The end of reciprocity was a deal breaker. But, that is not their intent.

As for “misconceptions,” Mark Twain quipped: “The difference between the almost right word and the right word is really a large matter—’tis the difference between the lightning-bug and the lightning.”

Happy new year!

RussPhoto of Russ Poulin

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

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Department of Education State Authorization Regs – Reactions and What’s Next?

It has been a busy few days since the U.S. Department of Education released the final version of its “State Authorization of Postsecondary Distance Education, Foreign Locations” regulations. You can see Cheryl Dowd’s and my initial take on the final rules, in which we were fine with many of the provisions, but alarmed at the changes regarding reciprocity.

In this post, we thought you would like to see some of the reactions issued thus far…

1) National Council of State Authorization Reciprocity AgreementsNational Council for State Authorization Reciprocity Agreements log

In a statement released on Tuesday, the organization that manages the SARA agreement, finds the change to the reciprocity definition puzzling:

“A ‘reciprocity agreement’ that would satisfy ED’s definition strikes us as no reciprocity agreement at all.” 

We agree. NC-SARA concludes with:

“We will continue to review the implications of these rules and communicate with our partners in the SARA initiative and with others.”

2) Cooley, LLP 

Cooley has followed every aspect of state authorization rules for decades. On Tuesday, they joined us in the head-scratching about the Department’s flawed logic in changing the reciprocity definition:

“This approach flies in the face of the very purpose of SARA, (and any reciprocity agreement) which is to provide a common set of authorization laws and institutional standards to which all participating states would agree. This unexpected change could therefore undo years of work to create a streamlined system for state licensure of distance programs, replacing a patchwork of laws, rules, and requirements that were extraordinarily burdensome on institutions and provided many students with substantially less protection than they have now under SARA. And of course ED’s position disregards the intent of the many state legislatures that have passed laws authorizing their state to participate in SARA over the last several years.” 

3) Massachusetts Executive Office of Education

So how did all of this happen? Massachusetts officials took credit in a press release on Monday:

“On Friday, the U.S. Department of Education announced the final state authorization regulations for postsecondary distance education, incorporating recommendations from the Massachusetts Board and Department of Higher Education, the Office of the Attorney General, and the Executive Office of Education to ensure that the final regulations do not curtail a State’s full authority to enforce its consumer protection laws. In the final rule, interstate reciprocity agreements cannot prohibit a state from enforcing its statutes and regulations, including those specific to all or a subset of educational institutions.”

Governor Charlie Baker applauds the Department’s actions:

“Massachusetts has the strongest consumer protection laws in the country, and we are thankful for the partnership with the Attorney General’s office on these efforts.”

What Massachusetts officials fail to mention in the state with the “strongest consumer protection” is that the state has never regulated purely online distance education, whereas SARA requires member states to do so. Where has the concern been for those students all these years?

Map of states that have joined SARA.

With recently added members New York, New Jersey, and (reportedly) Connecticut as SARA states, only three states (CA, FL, and MA) have not joined.

4) Inside Higher Ed

The history, the conflict, and the potential for the ultimate demise of the Distance Ed Rule were illustrated in a December 21, 2016 article in Inside Higher Ed:

“The rule-making process has been one of fits and starts, complete with court cases, delays and failed negotiations — and then a surprise last-ditch effort this summer. After collecting input on a draft this fall, the Education Department published the final rule in the Federal Register on Monday.

Yet the rule may never go into effect.”

The new regulations’ impact on SARA and the Department’s undermining of the work by state governors and legislatures to collaborate is described as follows:

“While department higher-ups have throughout the rule-making process reassured SARA that the rule would not undermine its work, the final rule includes a change that SARA’s national council on Tuesday described as “puzzling.”

The final rule states that reciprocity agreements can’t ban a state from enforcing its own laws, which SARA said suggests the Education Department will recognize reciprocity agreements that allow states to continue to enforce their own laws — even though they have entered an agreement to share a common legal framework.”

That statement ignores the fact that the governors, legislators, and/or other officials charged with overseeing higher education voluntarily joined the reciprocity agreement. Additionally, The Century Foundation is cited as one of the organizations pushing for the SARA limitations arguing that SARA “opens the door for ‘predatory online education companies’ to take advantage of students’.  Yet, The Century Foundation among a few other critics do not acknowledge that without SARA there are more than 25 states that do not provide any oversight of institutions providing online education. Under SARA those students are now protected.

5) This Regulation Will Probably Be Terminated 

We had a conversation with a knowledgeable person who assured us that there will be a bill to end this regulation. Using the Congressional Review Act makes the process of undoing this regulation fairly easy when one party controls both houses of Congress and the Presidency. The jubilation in Massachusetts and the Century Foundation is likely short-lived.

Meanwhile, state regulations are still in place and institutions should continue to follow those rules. If you or your institution has opinions on this regulation, you should share them with your Congressional Representative and Senators.

WCET State Authorization Network logo.

6) ‘Next Steps’ from the WCET State Authorization Network

The two of us had a long discussion about this on Monday. SAN members can expect to participate in more discussions regarding further recommendations on what next steps institutions should be taking. Look for more recommendations in the new year.

In the meantime, there are five important things for all institutions to remember:

  • Follow State Laws. All institutions must continue to follow the state’s laws in the states where the institution conducts activities, such as marketing, enrolling distance students, conducting face-to-face workshops, practica, or internships in another state.
  • Follow Federal Notification Rules. Federal regulations continue to be in place that require an institution to provide institutional information per 34 CFR 668.43, which includes providing a complaint policy in the states for which the institution participates in activities outside of the home state of the institution.
  • Be Sure Not to Misrepresent Your Offerings. Federal regulations continue to be in place to prohibit an institution that participates in Title IV programs from engaging in “substantial misrepresentation” about the academic programs, financial charges and the employability of its graduates.  34 CFR 668.71 * “intent” is not a necessary factor to determine whether a school has engaged in misrepresentation.
  • SARA Institutions Follow SARA Policies. An institution participating in SARA that has students in another SARA state must follow the unified policies and standards as agreed to by the states approved by SARA. These policies and standards include additional notifications and disclosures concerning students participating in programs leading to professional licensure.
  • Be Student-Centric with Information. Regardless of the requirements previously stated, to best serve students, institutions must provide students with the information necessary for them to succeed with their academic programs and for the credentials earned to then be useful in the location of the student.

We hope that you have happy holidays and a wonderful new year.Cheryl Dowd

Cheryl Dowd
State Authorization Network


Russ Poulin
Director, Policy and AnalysisPhoto of Russ Poulin with a bat.
WCET – WICHE Cooperative for Educational Technologies

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