e-Literate

Present is Prologue

Tag: WCET

  • Is the DOE backing down on proposed State Authorization regulations?

    Now witness the firepower of this fully written and delivered WCET / UPCEA /Sloan-C letter!

    – D. Poulin

    One of the policies that we’re tracking at e-Literate is the proposed State Authorization regulation that the US Department of Education (DOE) has been pushing. The latest DOE language represents a dramatic increase in federal control of distance education and in bureaucratic compliance required of institutions and states. In the most recent post we shared a letter from WCET, UPCEA and Sloan-C to Secretary Duncan at the DOE.

    What does it take to get all of the higher education institutions and associations to agree? Apparently the answer is for the Department of Education to propose its new State Authorization regulations. [snip]

    Here’s what is newsworthy – the idea and proposed language is so damaging to innovation in higher ed (which the DOE so fervently supports in theory) and so burdensome to institutions and state regulators that three higher ed associations have banded together to oppose the proposed rules. WCET (WICHE Cooperative on Educational Technologies), UPCEA (University Professional and Continuing Education Association) and Sloan-C (Sloan Consortium) wrote a letter to Secretary Arne Duncan calling for the DOE to reconsider their planned State Authorization regulations.

    While it is unclear how direct an impact the letter had, yesterday brought welcome news from Ted Mitchell at the DOE: they have effectively paused their efforts to introduce new State Authorization regulations. As described at Inside Higher Ed: (more…)

  • WCET, UPCEA & Sloan-C call on DOE to change State Authorization proposal

    What does it take to get all of the higher education institutions and associations to agree? Apparently the answer is for the Department of Education to propose its new State Authorization regulations.

    As part of DOE’s negotiated rulemaking process over the past half year representatives from schools (Columbia University, Youngstown State University, Benedict College, Santa Barbara City College, Clemson University, MIT, Capella University) to higher ed associations (WCET) were unanimous in their rejection of the proposed State Authorization rules. As Russ Poulin wrote for WCET:

    On Tuesday May 20, the Committee we had our final vote on the proposed language. I voted “no.” I was joined in withholding consent by all the representatives of every higher education sector. Nine out of sixteen negotiators voting “no” is a high ratio.

    Note that only one of the mentioned groups is a for-profit university – the purported offenders causing the need for the regulations. I wrote a post arguing that the proposed rules represented a dramatic increase in control over distance education that would cause a significant increase in compliance and administrative overhead for both colleges / universities and for states themselves.

    In the end, predictably, the rulemaking process ended in a lack of consensus that allows the DOE to propose whatever language they desire. The latest proposal was from DOE, and it would make sense for the final proposal to follow this language closely.

    Here’s what is newsworthy – the idea and proposed language is so damaging to innovation in higher ed (which the DOE so fervently supports in theory) and so burdensome to institutions and state regulators that three higher ed associations have banded together to oppose the proposed rules. WCET (WICHE Cooperative on Educational Technologies), UPCEA (University Professional and Continuing Education Association) and Sloan-C (Sloan Consortium) wrote a letter to Secretary Arne Duncan calling for the DOE to reconsider their planned State Authorization regulations. As the intro states [emphasis added]: (more…)

  • A response to new NCES report on distance education

    By Phil Hill and Russ Poulin, cross-posted to WCET blog

    Last week the National Center for Education Statistics (NCES) released a new report analyzing the new IPEDS data on distance education. The report, titled Enrollment in Distance Education Courses, by State: Fall 2012, is a welcome addition to those interested in analyzing and understanding the state of distance education (mostly as an online format) in US higher education.

    The 2012 Fall Enrollment component of the Integrated Postsecondary Education Data System (IPEDS) survey collected data for the first time on enrollment in courses in which instructional content was delivered exclusively through distance education, defined in IPEDS as “education that uses one or more technologies to deliver instruction to students who are separated from the instructor and to support regular and substantive interaction be- tween the students and the instructor synchronously or asynchronously.” These Web Tables provide a current profile of enrollment in distance education courses across states and in various types of institutions. They are intended to serve as a useful baseline for tracking future trends, particularly as certain states and institutions focus on MOOCs and other distance education initiatives from a policy perspective.

    We have previously done our own analysis of the new IPEDS data at both e-Literate and WCET blogs. While the new report is commendable in its improved access to the important dataset, we feel the missing analysis and potentially misleading introductory narrative takes away from the value of this report.

    Value of Report

    The real value of this report in our opinion is the breakdown of IPEDS data by different variables such as state jurisdiction, control of institution, sector and student level. Most people are not going to go to the trouble of generating custom tables, so including such data in a simple PDF report will go a long way towards improving access to this important data. As an example of the data provided, consider this excerpt of table 3:

    NCES Table 3 excerpt

    The value of the data tables and the improved access to this information are precisely why we are concerned about the introductory text of the report. These reports matter.
    (more…)

  • DOE Doubles Down on State Authorization: 25x increase in regulatory language

    Now that the Kabuki Theatre of the Department of Education’s negotiated rulemaking process has finished its penultimate act, can we all act surprised that the likely result includes the proposed State Authorization regulations growing by a factor of 25 with no comments allowed by one of the groups most affected?

    The gist of State Authorization is to force distance education and correspondence programs to comply not only with their home state regulations but to also comply with regulations for any state of residence for students. The proposed regulations from 2010 (struck down by courts in 2011) came in at 75 words:

    §600.9(c) If an institution is offering postsecondary education through distance or correspondence education to students in a State in which it is not physically located or in which it is otherwise subject to State jurisdiction as determined by the State, the institution must meet any State requirements for it to be legally offering postsecondary distance or correspondence education in that State. An institution must be able to document to the Secretary the State’s approval upon request.

    The most recent submission from DOE comes in at 1,912 words. You can read the full text here. This growth in regulatory language will have real costs. Today the president of Saint Leo College described how much of the administrative bloat in campuses is due to increasing federal regulations.

    Let me be clear, not all of the increases in college tuition and administrative bloat are caused by regulation, but some are—and far more than you think.

    (more…)

  • Proposed State Authorization: Dramatic increase in federal control of distance ed

    The Department of Education (DOE) released their proposed State Authorization regulations this week as part of the negotiated rulemaking process that seeks to replace previous rules struck down by courts in 2011. While the new process is more transparent than before (which was the basis of the court rulings), the proposed rulings would represent a dramatic increase in federal control of distance education and compliance burden for institutions. Greg Ferenbach from Cooley LLP noted these changes in a listserv discussion at WCET [used by permission from author, emphasis added]:

    What I don’t think many folks appreciate … is this proposal would be a huge change from the way things work today. From a quick read, it appears as though the proposal would require all states to authorize distance ed (with no exemptions for accreditation, etc.). Basically, this would be a mandate to either obtain specific state approval or participate in reciprocity as a condition for continuing to offer distance education with federal aid.

    Note that this is quite different from the last rule, which only mandated that you need to meet state requirements, if any, and thus it appears to impose a huge new burden on states and institutions. Think at least double.

    (more…)

  • WCET Post on Distance Education Misconceptions

    It is gratifying to see WCET pick up the mantle with their analysis of distance learning based on the new IPEDS data. They have several posts up already, and today’s post is quite good and important. If only more people jumping into the fray on higher education history and reform would start with a grounding in facts, the public debate and resulting recommendations would be much more useful.

    It is surprising how many times people conflate distance (or online) education with for-profit institutions. Often these are people who should know better, whether in Congress, the press, research universities, or other higher education pundits. Certainly, the for-profits have had a huge impact on the distance education world, but maintaining unfounded perceptions does not inform policy or practice. Some examples: (more…)

  • Mind the Gaps: WCET survey adds valuable context

    This week the WICHE Cooperative for Educational Technologies (WCET) released its Managing Online Education survey results that were previewed at the WCET13 conference in November. Despite all of the talk about the potential data-driven decision-making in higher education, it is remarkable how little we know.

    Course Completion

    Based on media coverage, the WCET survey results that are grabbing people’s attention:

    • For institutions reporting both completion rates, the on-campus completion rate was better than the online rate by an average of less than 5 percent
    • Institutions had trouble providing completion rates with 65 percent not being able to provide an on-campus rate and 55 percent not reporting an online rate

    These factors were covered quite well at Inside Higher Ed:

    Some respondents blamed the lack of data on course catalogs that don’t specify if a particular section of a course is online or not. Distance education providers have for years fought to eliminate the stigma of online courses’ implied lack of quality, and the shift toward an equal billing makes it difficult to distinguish between different forms of course delivery.

    (more…)