1. Auditing Distance Education
LeBaron Woodyard, Ph.D
Dean, Academic Affairs
Community Colleges Internal Auditors Conference
May 4, 2017

2. Topics DE Definitions (CCR title 5, 55200 et seq)
Regular and Effective Contact
DE Attendance Accounting
Hybrid Courses
Residency Determinations
Case Study: San Francisco City College Audit

3. Distance Education: Definition & Application
Instructor and student are separated by distance and interact through technology
CCR title 5, section 55200
51% of instruction is distance in lieu of face-to-face
CCR title 5, section 55210
Distance Education Guidelines 2008
Subject to requirements that may be imposed by the Americans with Disabilities Act and section 508 of the Rehabilitation Act of 1973, as amended
42 U.S.C. §12100 et seq and 29 U.S.C. §794d

4. Distance Education: Definition & Application (continued)
Must undergo separate review and approval by the district’s adopted procedures
CCR title 5, section 55206
Course quality is the same as traditional classroom courses
Determinations about quality must involve faculty.
CCR title 5, section 55202
District governing boards must ensure “regular and effective contact”
CCR title 5, section 55204

5. Side Note: Regular & Effective Contact CCR title 5, section 55204
Includes:
Group or individual meetings
Orientation & review sessions
Supplemental seminar or study sessions
Field trips
Library workshops
Telephone contact
Correspondence
Voice mail
“other activities”
Caveats:
Academic and professional matter pursuant to section et seq.
Consistent with guidelines issued by the Chancellor pursuant to section 409 of the Procedures and Standing Orders of the Board of Governors

6. DE Attendance Accounting
Most DE courses follow the Alternative Attendance Accounting Procedures
Any course that does not meet on a regular basis regardless of percentage of time will require use of the alternative attendance accounting procedure.
Example:
90% regularly scheduled
10% not regularly scheduled

7. “Hybrid” Courses
No official definition of “hybrid course” in California statute or regulation or distance education guidelines
However if less than 51% is at a distance then by deduction the course is a “hybrid course”
College’s must consider the course regularly scheduled time as a whole to determine accounting procedure, the entire course must meet at the same time, all the time.

8. DE and Residency Determinations
Issue:
Audit Test 425 – Residency Determination for Credit Courses is a delay for students enrolling in courses through the Online Course Exchange* and may cause potential audit findings for colleges offering those courses if a college accepts another college’s determination and does not determine it themselves.
*The Online Course Exchange is a project of
the Online Education Initiative

9. DE and Residency Determinations
Recommendation:
Clarify statutes and guidelines for residency determination requirements among colleges offering courses in the Online Course Exchange to allow the teaching college to accept the determination of the home college and which will eliminate enrollment delays and not subject the college to an audit exception.

10. DE at San Francisco City College
“CCSF can’t prove it taught 16,000 students,
must pay $39 million”
–San Francisco Chronicle
NOT an indictment of the quality of their distance education program

11. DE at San Francisco City College
Official record keeping in the Learning Management System (LMS) software was not enforced
Classification of “To Be Arranged (TBA)” courses as DE but they were not held to the same standard as a DE course
Not required to use the LMS
Not coordinated with Education Technology Dept
No DE addenda created

12. San Francisco City College January DE Audit
Approximately 3 month process
Pre-work required college to provide DOE with administrative-level access to their LMS prior to first visit
Audited , , and

13. San Francisco City College January DE Audit
- Continued
DOE thoroughly examined courses
Found problems with the CCSF use of META courses that contained multiple course record numbers
When DOE could not find a student it was because they were dropped – SFO re-enrolled the students with activity and the grades were restored.

14. San Francisco City College January DE Audit
- Continued
DOE thoroughly examined courses (continued)
Explored “substantive interaction” (equivalent to regular and effective contact)
In online discussions looked for faculty prompting
Video FAQs were not adequate
External website vendors did not archive substantive feedback

15. San Francisco City College January DE Audit
- Continued
Result
No significant findings
Expedited Final Program Review – no formal report, no rebuttal
Some problems with documentation and substantive interaction

16. THANK YOU
LeBaron Woodyard, Ph.D., Dean, Academic Affairs Erin Larson, Specialist in Academic Planning and Development Education Programs and Professional Development Unit Academic Affairs Division California Community Colleges Chancellor’s Office