CAROLYN HOLCROFT, FOOTHILL COLLEGE, CURRICULUM COMMITTEE MEMBER MICHELLE PILATI, ASCCC PRESIDENT Revisiting the Separate Approval Process for Courses Offered Via Distance Education

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?

WHAT IS THE GOAL OF THE SEPARATE APPROVAL PROCESS? Why separate approval?

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

WHAT CRITERIA SHOULD YOU CONSIDER? What criteria do you consider?

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

WHY IS REGULAR EFFECTIVE CONTACT MORE IMPORTANT THAN EVER BEFORE? Why regular effective contact?

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

Last Date Of Attendance (LDA) How do you certify LDA if you aren’t taking attendance? What suffices as “taking attendance” in distance education?

Determining LDA/Effective Withdrawal Date Institution may either use:  the mid‐point of the financial aid payment period, or  it may document the student’s actual LDA as determined by his or her last known “academically related activity.”

For Distance Ed… Traditionally we’ve 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 student’s LDA in an “academically related activity”

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 practices—we’re in the same net “Reaction of legislators to the anecdote” MICHAEL GOLDSTEIN

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 institution’s compliance with Title IV requirements

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:

Regular and Substantive Interaction discussion board posts, completed assignments, or electronic conversations with faculty Sort of sounds like “regular and effective contact”, eh?

Ouch-comes? Dept. of Ed. Admits that there is NO prior general guidance supporting it’s position However, it has retroactively applied the new standard to prior year’s 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

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.

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.

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.

Sample LDA Policy—Comments? 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 student’s work until the point of dropping the student.

Thanks!

Resources WCET: distance-educationhttp://wcet.wiche.edu/advance/financial-aid-and- distance-education

State Authorization Update Our theme should be BE PREPARED For July 1, 2014

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)

USDOE won’t 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

Issue of State Approval Steps for now: 1. Identify your out of state, online only, students 2. Check to see what the states involved require 3. Get your materials together that meet those requirements 4. Contact the appropriate state regulators to see what you need to do.

State Approval Resouces  State Higher Education Executive Officers – list of state requirements.   WCET Resource Page   Conference: State Authorization: Managing for Success: authorization101session639 authorization101session639

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?

What’s next? Defining the online credit hour The continuing saga of State Approval Academic Integrity Accreditation stories

Accreditation Stories

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.

Baker College Audit : did not maintain records that were adequate to support its determination of attendance for DE students : when DE students unofficially withdrew or dropped out, college incorrectly identified when students began and ceased attendance

Baker College Audit Random sample 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.