Carolyn Holcroft, Foothill College, Curriculum Committee Member

1
Revisiting the Separate Approval Process for
Courses Offered Via Distance Education

• Carolyn Holcroft, Foothill College, Curriculum
  Committee Member
• Michelle Pilati, ASCCC President

2
Overview

• Why separate approval?
• What criteria should your curriculum committee be
  considering?
• Why regular effective contact?
• Why is regular effective contact more important
  than ever before?

3
Why separate approval?

• What is the goal of the separate approval process?

4
Why separate approval?

• Articulation?
• Compliance?
• Accessibility?
• Regular effective contact?
• Quality?

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What criteria do you consider?

• What criteria should you consider?

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Compliance

• Title 5 Mandates
• Separate review
• Regular effective contact
• Accreditation standards
• Section 508 (accessibility)

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Why regular effective contact?

• Why is regular effective contact more important
  than ever before?

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Financial Aid!

• Last Date Of Attendance (LDA)
• The date an institution is expected to use to
  calculate amount of Title IV refund when a
  student withdraws from a program
• The later the LDA the less refund

9
Last Date Of Attendance (LDA)

• How do you certify LDA if you arent taking
  attendance?
• What suffices as taking attendance in distance
  education?

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Determining LDA/Effective Withdrawal Date

• Institution may either use
• the mid-point of the financial aid payment
  period, or
• it may document the students actual LDA as
  determined by his or her last known academically
  related activity.

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For Distance Ed

• Traditionally weve determined LDA based on the
  last day a student entered a secure classroom
  site (logging in)
• USDOE has taken the position that logging in is
  NOT sufficient to document students LDA in an
  academically related activity

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Why all of these regulation issues?

• General mistrust of online education
• Reauthorization of the Higher Education
  Opportunities Act
• Financial Aid Fraud increase
• Private-for-Profits under fire for unethical
  practiceswere in the same net
• Reaction of legislators to the anecdote
• Michael Goldstein

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DE/ Last Day of Attendance, aka the R2T4
calculation Federal Guideline issued 2010

• Guidance with the new federal regulations
  requires evidence of academic engagement for
  online enrollments.
• ..accreditors are supposed to review whether the
  classes that institutions classify as DE involve
  active engagement of students
• if not, they are to be classified as
  correspondence education (ineligible for Title IV
  aid) and accreditor to review institutions
  compliance with Title IV requirements

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Implications for DE Defining Academic Engagement

• USDOE has begun retroactively enforcing this
  heightened standard that requires documentation
  of regular and substantive interaction between
  the students and faculty, through

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Regular and Substantive Interaction

• discussion board posts,
• completed assignments, or
• electronic conversations with faculty
• Sort of sounds like regular and effective
  contact, eh?

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Ouch-comes?

• Dept. of Ed. Admits that there is NO prior
  general guidance supporting its position
• However, it has retroactively applied the new
  standard to prior years program practices.
• The Ultimate Bad outcome An audit that finds
  that your program lacked sufficient engagement
  and should be classified as correspondence
  study which could make them ineligible to
  participate in the Title IV Programs.

Michael Goldstein, Dow Lohnes PLLC Friday,
October 28, 2011
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Classes Held to Different Standards?

• So evidence of academic engagement required
  for online enrollments
• vs requiring evidence of physical presence in
  the classroom for the face to face programs.

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Pre-emptive Solutions?

• Make it clear to online teaching faculty that CMS
  statistics are not enough.
• Define and enforce Regular Effective Contact at
  your college.

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Pre-emptive Solutions?

• LDA policy is created and enforced that includes
  academic engagement (activity).
• Instructors save work of the student dropped and
  document when the activity stopped.

20
Sample LDA PolicyComments?

• When a student has not participated in
  discussions or other forms of communication
  and/or has not submitted assignments for two
  consecutive weeks, the instructor will attempt to
  contact the student and notify them that they
  have 5 days to complete the missing work or be
  dropped from the course.
• The instructor will document the students work
  until the point of dropping the student.

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Thanks!
22
Resources

• WCET http//wcet.wiche.edu/advance/financial-aid-
  and-distance-education

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State Authorization Update

• Our theme should be
• BE PREPARED
• For
• July 1, 2014

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What do you mean, State Authorization??

• October 2010 USDOE released program integrity
  regulations
• Institutions offering distance ed or
  correspondence education need to acquire
  authorization from any state in which it
  operates
• Required for students of that state to remain
  eligible for federal financial aid
• Institutions have until July 1, 2014 to obtain
  authorization(s)

http//wcet.wiche.edu/advance/state-approval
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USDOE wont initiate any action to establish
repayment of liabilities before July 1, 2014

• Evidence of good faith efforts by institutions
  could include any one or more of the following
• Documentation that an institution is developing a
  distance education management process for
  tracking students' place of residence when
  engaged in distance education
• Documentation that an institution has contacted
  their State directly to discuss programs the
  institution is providing to students in that
  State to determine whether authorization is
  needed.
• An application to a State, even if it is not yet
  approved.
• Documentation from a State that an application is
  pending

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Issue of State Approval

• Steps for now
• Identify your out of state, online only ,
  students
• Check to see what the states involved require
• Get your materials together that meet those
  requirements
• Contact the appropriate state regulators to see
  what you need to do.

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State Approval Resouces

• State Higher Education Executive Officers list
  of state requirements.
• http//www.sheeo.org/stateauth/stateauth-home.htm
• WCET Resource Page
• http//wcet.wiche.edu/advance/state-approval
• Conference State Authorization Managing for
  Success http//www.slideshare.net/WCETConference2
  010/state-authorization101session639

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• Does your local process for reviewing distance
  education courses do all that it can and should
  do?
• Are your local processes designed to not only
  ensure that all faculty teach to the course
  outline of record, but to do all that they can to
  ensure the integrity of your distance education
  offerings?
• The scrutiny being applied to distance education
  from others outside our colleges is greater than
  ever before is it time to revisit the scrutiny
  applied by local curriculum processes?
• How can your curriculum approval process be
  improved to not only meet existing Title 5
  mandates, but also facilitate student success and
  increase the quality of your distance education
  offerings?

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Whats next?

• Defining the online credit hour
• The continuing saga of State Approval
• Academic Integrity
• Accreditation stories

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Accreditation Stories
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Baker College Audit

• For DE students who unofficially withdrew or
  dropped out, the College did not correctly
  identify when the students began and ceased
  attendance when it
• (1) determined students' eligibility for Federal
  student aid disbursements and
• (2) performed return of Title IV aid
  calculations.

33
Baker College Audit

• 2006-2007 did not maintain records that were
  adequate to support its determination of
  attendance for DE students
• 2007-2008 when DE students unofficially withdrew
  or dropped out, college incorrectly identified
  when students began and ceased attendance

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Baker College Audit

• Random sample - 100 of 2,338 DE students who
  received Title IV, HEA program funds and received
  a failing grade or withdrew from at least one
  class, during the fall 2007 and winter 2008
  quarters.
• 22/100 errors found. Of those 22, 11 students
  had errors that had or could have had a financial
  effect on the amount of funds the College was
  allowed to retain.