Distance Learning and Educational Innovation Subcommittee – Afternoon session


Gregory did you want to impart any rules
about time for this afternoon okay we’ll start up again and welcome back hope you
had a nice lunch the rest of the afternoon I’ll tell you what we hope to
do I want to finish the discussion of a credit hour going to turn it back over
to Beth Daggett from Accreditation who will discuss the definition of pre
accreditation and I want to I want to move that discussion up because just
being mindful of Beth’s time in allowing her to get her portion of it out of the
way you can ask any questions you want to first she may be around they don’t
know what else she has to do the rest of the day but um I want to get that out of
the way so so we don’t inconvenience Beth any more and then after that we
will go into the discussion of distance education which David will lead and I
anticipate that will take some time and we still have this placket over here and
yet we still were discussing credit hour right now before we continue with the
discussion in credit hour I’m going to add one one thing other thing about this
as we go through the definition you see the proposed language we have here and I
want to reiterate that sort of going back to what Amory said that this this
this language we have here all of our language is a there’s an opening
position we are not at all a verse to you coming up with other other other
language that you think might be more appropriate so as you look at this
definition if you feel that what we have here is not a bridging the term robust
they don’t want to be using it too much but if you don’t if you feel there needs
to be more or a firmer definition we’re open to that we just ask that when you
consider that language you bear in mind other modes of instruction or innovative
modes of instruction other other than the traditional brick-and-mortar sitting
in a classroom type environment which which this current definition sort of
tied to so we would ask that you think about that and we
we don’t it doesn’t have to be done today you know we can you can go back
and give that consideration if you have some language you’d like to throw out
there maybe there’s something we can all agree on if not we can at least present
where the where the committee is so why don’t we pick up without better actors
and bad actors just recognizing if you’re gonna hook up come up with
alternative language that the Department oversight responsibility is broader than
your sector that each of you are representing so that when you’re looking
at it from the he said different modes of the disbursement of Education but
also just from an oversight perspective the department has to look at the whole
range one more determine and what might that suit for the taxpayers and the
students and for oversight responsibilities so when you’re thinking
about language just wanted you to keep that in mind as well all I’m trying to
say is that when you’re looking at language there’s a range of entities
that we deal with in terms of oversight in terms of applying the regulatory
language so all I’m saying is if you’re gonna come up with alternatives to the
language that was proposed just keep in mind that there’s different sectors that
we deal with it can’t just be for a competency-based situation so we can
continue with any comments related to credit hour Julian so I just have a
couple other comments I think mostly in response to what folks have talked what
we talked about before lunch so I hope we all remember what we talked about
before lunch I barely do so one I just wanted to your comment about a creditors
sort of having oversight of academic quality chole lined with that I’m
struggling a little bit I think in this conversation because I think credits are
really the currency through which federal financial aid funds are
dispersed and so I think it’s hard I mean it’s sort of like splitting the
baby a little bit but I think we need to keep that
lenz in that perspective because it can provide a pathway for fraud and abuse to
happen but I don’t I just want to be clear that I don’t disagree with you
that sort of their creditors maligne is for sure around academic quality but I
think it gets messy when we sort of conflate the two the second thing I was
gonna say was I don’t even know what my note means anymore so I’m gonna skip
that one and then I just want to reiterate that I think it would be super
useful for this group if we can maybe you can we can provide copies before the
next subcommittee meeting of the guidance that I mentioned which is Jan
1108 and I’m happy to read it if it’s useful but there-there was flexibility
given by the department after this definition was made that I think is
really important to addressing some of the needs for innovation but still
safeguarding taxpayer funds and so I’d like to sorry I’m being duplicative but
I would like to again reiterate that I think it’s worth considering adding some
of that language and keeping the existing definition because I’m
struggling I would love to hear some examples about how this definition has
inhibited innovation given one the pathway for direct assessment which
allows flexibility from the credit hour and then to the guidance that the
department issued subsequent to the credit hour definition oh and then at
lunch two people asked me if I could just reiterate a conversation that
happened from the full committee meeting earlier this week which was around
trying to brainstorm ways to allow accreditors software flexibility to
institutions who are interested in innovating and I think they’re right
that there’s a huge tie there could be potentially a tie in here if we’re
looking for ways to allow individual institutions to innovate so I think I’m
making up these rules as I go but as part of the read out back to the full
committee I think if we have thoughts maybe about how that could look with
respect to just inside and innovative programs I think it’s appropriate for us
to bring those back the placards are up for the same subject okay
so David so I wonder and David I was thinking about your comment that regular
and substantive as part of the statutory requirement for online or distance
education so we don’t have much flexibility and
of doing anything with that right not with the basic the basic concept now we
can clarify it and we can give more definition around it but the concept
itself is enshrined in law and we have to and we have to start there okay so if
that’s the case why don’t we just marry regular and substantive directly to the
credit hour upfront can you explain that a little bit more yeah so so I’m hearing
around the table some concern with the current definition of the credit hour
maybe too wishy-washy may create problems etc etcetera right – and yet
when we get to the distance education criteria you put a lot more definition
action for that particular modality without addressing the issue in the
classroom so why not just address the issue comprehensively let me so let me
restate and see if I’m understanding what you’re what you’re suggesting so
you would suggest trying to create a definition for the credit hour that is
comprehensive enough to also include a discussion of the regular and
substantive interaction requirements so that we could refer back to it in the
distance ed Lange definition no I mean sort of what I’m suggesting is put
regular and substantive in as part of the definition of the right credit hour
so so you you would want the concept of regular and substant interaction to
apply in you know as schools are calculating credit hours yeah if we’re
if we’re confined to it in distance I’d then let’s embrace it holistically can I
make a suggestion that maybe you could give us a rough draft you think well
yeah because that’s going to be maybe a little bit about it but I mean I do
think the the department would be interested in
seeing the suggestion and talking through it sure I just wanted to make
sure that there would be nothing statutorily that would prohibit and I
don’t think there is but that wouldn’t only be the only concern I would have
from looking at but I I would take it back and make sure but I think it’s a
good point yeah I mean it just seems to me that on the one hand it’s what from a
competency-based perspective a lot of institutions gripe about and at the same
time I think everybody understands the intention behind it so if we if we honor
the intention and are serious about it then it seems to me that it should apply
across the board and then you get and then I think if you incorporate it into
the definition the credit hour you get a rid of a lot of the fuzziness and more
people are more comfortable Jodie thanks I just wanted to respond to a couple of
the comments just with respect to David I would really hesitate before
incorporating a regular and substantive interaction into the credit hour
definition simply because regular and substantive interaction is something
that applies specifically to the distance and it context it doesn’t apply
to cut the classroom setting for obvious reasons and so if you incorporate that
concept into credit hour then you’d be applying it I know for our sector her
for the private nonprofit sector that that I’m not clear on why that edition
would be necessary given that that there we were already dealing with a classroom
setting so you don’t have to verify that there is that regular sort of
interaction going on so I I have hesitations about that proposal and then
Julie and I just wanted to respond to your comment which I think again maybe I
was falling victim to Denise’s who aren’t hang in the beginning I mean
I was speaking about the credit hour definition and partly from the view of
our institutions who operate under a shared governance model where any
curricular changes have to be approved by faculty and so there already are say
guards in that context but yes we definitely share concerns about
potential for fraud and abuse I already have two thoughts I don’t think that the
fact that something is taught in a classroom makes it automatically assume
that there’s regular in substance of interaction I think we’ve seen
increasingly classrooms where you log into a site off of that that they do not
meet as scheduled it’s right I think just jumping to the one automatically
assumes the other is happening I think the jump but I did want to go back that
I hope somewhere in here is I’m listening to the conversation I hope we
can come back to this after we hit direct assessment and distance education
because I I’m so struggling a bit and I can’t remember who said it maybe Gillian
that some of what I think might be the confusion in translating and being an
institution that gets a lot of transfer students trying to evaluate what is what
and I’m sitting on both sides of the fence I’m concerned with the current
definition but I have concerns about making it to all over the place so I
guess I would ask that we come back by that after we go farther down the list
into direct assessment that we come back to this and don’t assume it’s a done
deal Julian yeah David appreciate what you’re
trying to do I think though putting it putting regular and substantive in
credit hour I’m not sure makes sense because you can have a correspondence
program that also is a credit hour requirement which by definition still
correspondence programs don’t have regular and substantive so I’m not sure
it seems like we would be creating a requirement that all credit our programs
have regular and substantive but we also have correspondence courses which don’t
so I don’t know hopefully I mean clear but I’m just not I’m not a lawyer so I’m
not sure but it seems like we wouldn’t be able to do that without getting rid
of correspondence education altogether if only if we we put a carve-out and
then that said that correspondence was somehow treat it differently you know
you’d have to have some kind of something else that applied in that case
if we did it that so then like a different credit our definition for
correspondence I’m not coming to that neck rag so
anyway this one no I was just gonna say that Jillian I think I mean it’s done in
the law all the time in terms of carving out so I mean I don’t know that that
would preclude it I understand your concerns but I just think from a legal
matter you could definitely carve out an exception for correspondence because it
would not apply at all there David I think that it’s not an automatic thing
that just because you have classroom instruction then you have regular and
substantive interaction and so if you do great then there’s nothing to worry
about by putting it into the credit hour if if you don’t then you should and then
there’s no problem with putting it in the credit hour now the Jillian to your
point I had not thought about that so if there’s a way to carve it out okay if
that’s too cumbersome I don’t know but but I don’t think that I think that the
presumption is that face-to-face instruction automatically has regular
and substantive interaction either that’s a leap we know that’s not true just a couple quick points there now to
David I thank you David for I think we need some creative solutions to just
some of these things and start questioning some some assumptions I’m
not sure I’m quite on board with where we’re going with that but I think we
need to start thinking about as we’re getting into these about breaking some
of these were there at the other thing that is kind of an underlying concern I
have I’m gonna kind of graph in a different path here is that that there’s
things that we haven’t got to yet that have to do with the definition of
accreditors and who’s gonna be a creditor and and it seems like there’s a
lot of interest in creating lots of new accrediting agencies said that could
come along and I have to admit that I mean maybe it’s a biased I have that I’m
probably more willing with the current set of a creditors to allow for say you
know for some of this uncertainty about what’s going to have or that the
accreditors will do the right job when there’s a whole list of people who may
be coming in that I don’t know who they who they are it makes me want to be more
conservative at this point even though I’m in the innovation field you know
that I want to want to be conservative about well who’s going to be the one
who’s actually over overseeing that and that that it’s not only this issue but
there’s several issues where I have that I’m conflicted in that way thanks Leah so I’m coming at this from the
perspective of a gatekeeper financial aid and just from experience having a
framework that backs up the student work and the student learning that goes into
that award of credit has proved over the last eight years to be a pretty useful
tool I’m concerned that we already kind of know the consequences for stripping
this definition away and leaving it to institutions and their creditors to
decide for themselves because we saw some past practices where that didn’t
work out very well and we saw financial aid
warded for courses and programs that didn’t have the backup of student work
and faculty assessment of outcomes behind it if you know consensus builds
around removing this definition and I think we have to look to the accrediting
community and the states to what their roles are going to be in reviewing how
we’re documenting the learning for students so I just I’m repetitive from
what I said before lunch but I’m just sitting here thinking about you know our
role here today is to have as best accountability for how we’re using our
financial aid dollars and the most responsible course of action we can take
for students in that Jodi yeah I just wanted to respond again about on the
regular substance of interaction question with respect to distance IDI
and with respect to putting it into the credit hour I and I take your point but
I also would my understanding of the regular and substantive interaction
language is that it’s in the statute only with respect to distance and I have
I wasn’t able to find it in my compilation right now
so I’d question whether what statutory authority there would be to apply that
requirement to institutions outside of distance education setting but I also
you know I my understanding is that those provisions were put in there in
part to verify that there was actually a student on the other end of the distance
ed program and with a classroom setting you don’t need that right I mean that’s
the whole purpose behind regular substantive interaction requirement well
yeah I’m gonna couple of things first off that’s why I said before it is only
in the distance education definition but as I said before I don’t believe there’s
anything prohibiting it whether there’s a hook I have to go back and look
because it isn’t something that necessarily we had contemplated and I’m
gonna have to go back and see if that because you’re looking at is there we
call it a hook is there a hook in there that would allow us to do this so I
would have to look there’s something I’m going
to look into but it’s not just from an enforcement perspective it wasn’t and
Dave can jump into it wasn’t just whether there’s a student on the other
end it’s whether or not that student was doing more than I’m gonna sign on and
then I’m gonna go watch TV for five hours and then I’m gonna come back and I
just got fired you know I just did my work that’s what I meant yeah right it’s
more right I that’s because we do have that you know that issue but it was more
of the just signing in and walking away yeah I just follow on to that the the
distinction in the law is between correspondence courses and distance
education in both correspondence courses and distance education there’s an
expectation that the student is doing work the work is being completed
there’s grading and then there’s an eventual like establishment of how well
the student did and did they did they show that they completed the work but in
the case of distance education Congress specifically pointed out that there
needed to be interaction between the student and and faculty and and not
faculty but the instructor is that is the statutory language and that is
that’s different from just making sure that there’s a student on the other end
it’s essentially saying that there’s an expectation that there is an contact
between the student and the instructor in a more substantive and way I
shouldn’t use that term but in a way that doesn’t exist in the correspondence
environment and that and that is the distinguishing factor that they gave
aside from all the technology things that are also in the statutory
definition I just I’m trying to think of like implementation how would you look
at that in enlarge I went to large University a large university lecture
hall did you think about how that would you would envision that besides they I
know sometimes my daughter’s professors randomly click and things like that but
well so I mean that’s exactly what I’m thinking about right so I think we have
this bias to think that correspondence happens only at a distance but
correspondent study is exactly what you’re describing when those students
are surfing their phones and completely anonymous in a 500 room lecture and so
so if the whole idea here is about quality of education and this is one of
the ways to guarantee the quality then then we ought to make sure that those
students are getting the same quality or the same at least the same standards
apply as the students who are studying online and I would just look wondering
what kind of mechanisms you are thinking about well I mean you can do lots of
things you can you know a lot of schools obviously have some kind of breakout
sessions and they you know that kind of thing so that there is interaction with
the instructor on a regular basis but it would be presumably up to institutions
to figure out the solution here it was more of a cure no I’m with you Lee as
your placard up for her okay in that case it’s Amanda I think I have a
clarification issue um because there’s a difference with correspondence courses
in distance learning education correspondence for my understanding and
there’s like it’s written in the definite oil
there’s proposed changes also not in this one but in the original definitions
correspondence is more self-paced less regular interaction whereas distance
learning so as we’re having these conversations
about you know your suggest or David suggesting new language I think the
distinction between them for everyone should be really clear and the
implications will be different so if you’re proposing like a standard for a
credit hour it’s gonna be different for correspondence and distance learning you
can’t lump them together because they’re different even though they’re they can
be done there yeah there’s they’re different things the engagement piece
should still be there but like correspond like I think having an
example of like a large classroom and then and
comparing that to a correspondence course is different because more
self-pace an independent study whereas like you can make an argument definitely
that in a class where the instructor isn’t necessarily giving enough feedback
to a hundred class a student maybe burden to be self studied but that’s not
necessarily what we would hope to have but in correspondence it’s almost
embedded that you’re it’s a self-paced independent study scenario I just wanted
to make a clarification you can correct me if I’m wrong but just for everyone
appreciate that clarification and I think that’s a similar point to what
Jillian made earlier about the fact that the correspondence if you try to include
the concept of just a regular and substantive interaction and in in the
credit hour you couldn’t have the same one for distance ed or or the rest of
higher ed and correspondence because that correspondence simply doesn’t
require that and functions in a very different way Rudy one of the things
that I find fascinating about this conversation a bit is well we’re having
this as this is innovation there’s innovation happening in the traditional
classroom setting and one the question came how would you have substantive
interaction or know somebody who’s in a lecture hall what we’re seeing more and
more universities go toward clickers and their clickers are assigned to a student
so they can tell we put this question up who responded to it if they wanted to
they could track some type of engagement the flip side of that is the same
universities are also going to webcasting the lectures so that the
students don’t have to attend and they can get them later that they can listen
to them on their phones and things later so it’s I think in some ways we run into
a risk that I I know we have a lot of different ages here but we have people
who assume that traditional is as it was when we went to school and they’re
changing as well they’re flipping it as well as that they’re both moving away
from substance interaction and in some ways of doing things to try and solve
the lecture hall issue but I at some point I hope we reconcile the two a
little bit here my other piece I wanted to add on in with Russell is I I too
have some concern we mapped this out that there’s one
pathway we’re talking and I hadn’t really thought about it till I sat in
here thinking about what it means to say we want more competition among
regulators and I’m still trying to wrap my arms around what what that means and
what it might breed and how they would compete and I assume they’re competing
for institutional business but as we’re having that conversation and leaving
more and more up to the accreditors I and I just I’m just worried down
I hate keep saying downstream but I’m I’m worried as we look at that that
we’ve set up a competition among our creditors which I assume for business
and we’re saying they should be responsible for more and more things
which means what might attract a school Gillian yeah so great point and I would
say you know related to that as we have these conversations about all these
issues that you know that we all care about I’m not worried about the
institutions sitting around this table or even the universe of institutions
that exist today that are receiving title 4 funds and worried about new
institutions that see a pathway to siphon title for funds take our students
right because they don’t know the difference between your university in my
University and Russ’s College down the street I used to use this example
yesterday of somebody else Russ’s College down the street that doesn’t
have any faculty but if all of our institutions are eligible for the same
amount of title for there’s a real risk to tax taxpayer dollars right so I think
to your point as we think about increased competition from a regulation
from a regulator perspective and then creating inadvertent pathways where low
quality providers can pop up and I get it right I represent the for-profit
sector we’ve seen it happen in our sector where bad actors have popped up
and followed the money and so trying to protect against that happening while
still recognizing the need for innovation is a really hard place to be
in because we only know the actors that exist today right and we feel pretty
okay with that from a accreditation perspective from an institution
perspective but when we start creating the opportunity for folks to take
advantage of taxpayer funds and provide low quality educational options to
students and we’re really gonna run the risk of casting a bad light on higher
education in general and I would say related to that and then
I’ll stab to the comment earlier about we don’t need this regulation because
nobody’s breaking this rule it’s a little circular right because probably
people aren’t breaking this rule because they can’t and so I think suggesting
that we don’t need it because nobody’s doing it is just a fallacy
so PES won’t say in the interest to move things along we’ll take the remaining
comment then well hey if you want to go back and think about some language to
bring to us we certainly entertain that but then I think we need to move on to
want to get to distance today okay so okay Jessica last comment just
illustrate Julian’s point I’ve had over three dozen clients who attended a
school in New York City that on August 21st 2017 solicited enrollment for the
fall semester sent the whole school an email said hurry classes are filling up
took peoples enrollment both cash payments and title four on September 1st
2017 shut down on November 1st 2017 declared chapter 7 bankruptcy the
students who paid out of pocket that money has gone forever including
students who had to like borrow it from their jobs so I guess I just want to
underscore like this is a like a real problem that people face every day where
people enter this space and I don’t have I don’t know the intent of what happened
at the end there but it just seems like things went really bad really fast and
the money ended up in someone else’s pockets and it looks like there might
not be anything out of the chapter 7 bankruptcy for the students so I I
appreciate that point and it’s I just want to say it’s really real so as we
move away from this topic for now as Greg said we’re interested in
alternatives that you guys come up with keeping in mind what Greg said earlier
that we’re looking for things that can accommodate a variety of modalities of
Education while still you know ensuring innovation in that way but while also
addressing the concerns to the taxpayer for ensuring that there is you know a
currency that we can use to prorate title for aid and establish who’s
eligible so those are the those are sort of the twin things that we’re looking to
do with the regulation yeah I actually requested that it be
printed and the problem with Dear Colleague letters of people printing
them aren’t necessarily people spend a lot of time with your colleague letters
so if you know how they work you go in and you get the cover page but then you
must click on the attachment the attachment was not clicked on so
obviously it’s longer than one page and the this doesn’t do us any good so I’ll
without I’ll go back and try to get up I’ll get copies of that for everybody
you could find it if you have your phones it’s uh it’s Dear Colleague
eleven – Oh eight which you can find on ifap for probably just by googling yep well yeah so yeah we can send you the
link and then whoever Scott I think if you send it out or whoever does we
should send the QA that’s on the IFF website because it kind of recapitulates
what’s in the Dear Colleague letter but it’s the resource that most schools use
when they’re when they’re talking about this issue so yeah we’d be glad to do
that okay well right now I’m going to turn
over to Beth Daggett who’s going to discuss pre accreditation I don’t want
to stop your lively discussion but we thought it might be good just to get
this last strictly accreditation thing out of the way and then you guys can
focus on a lot of the other things that you’ve been discussing
I’m yes I’m sorry it has the pre accreditation definition it’s still in
Section six hundred point two it’s at the top of page six so you’ll see above there was a prior
pre accredited definition that was struck and then a new pre accreditation
definition was added if you’d like I can read the whole thing out but if all of
you have it in front of you I just to let you know the difference is the main
thing was and this is to go back to you know Amanda rightfully so bringing up
you know how does this affect the students is to add some additional
protections to students who are enrolled in an institution that’s pre accredited
that you know if that all credits and degrees earn by an institution that’s
listed as pre accredited by their accrediting agency would still consider
those credits would be considered as accredited by the secretary that if an
agency were to deny pre accreditation to an institution or program that there
would be some sort of time period to allow finishing of a certain either term
or the remainder of an academic year and it’d still be considered pre accredited
and then finally that an accredited institution couldn’t go from being
accredited to pre accredited by the agency unless there was a loss of
accreditation and then they came back and applied for initial accreditation
that so that the movement from accredited to pre accredit isn’t used as
like a negative action by an agency other than that the part at the
beginning which is just describing what the status of pre accreditation is and
what we feel that that represents so I’m happy to take any comments questions etc
Leah like so Beth can you maybe explain the basis for allowing the approval in
title for access to continue even though denied because that’s not a provision in
place for currently accredited fully accredited schools that get denied we
don’t have anything that says they get stay active in title four until the end
of the term so I’m just curious why we’re making that a provision for for
candidacy I think that the Department the administration’s intent is that pre
accreditation there’s usually there’s a you know a certain time period than what
you have to have have made that decision there’s also a lesser bar for an
institution or program usually to have that pre accredited status so for their
loss of that Achra Dacians usually an easier step for an agency to take and
also there’s usually not a teach out or teach out agreement or teach out program
and as you’ve seen there’s other definitions that have been strengthened
in those areas that wouldn’t apply necessarily to a pre accredited
institution so it was to protect students that perhaps were caught at an
institution and then this would give them the time to continue to finish that
particular part of their study and then possibly hopefully be able to transfer
somewhere else to then be able to complete their study regardless of where an institution is in
the spectrum of applying for accreditation they should know where
students can transfer their credits if something happens I mean there should
always be a contingency in place whether you’ve been accredited 3 5 10 20 30
years a responsible institution knows how to take care of their students I
guess I just know I just find that language very curious I’m not sure it’s
such a good idea but would love to hear more maybe from other experienced voices
in the group right and you know as was was said before as the this language is
what was had been proposed by the department and that there’s obviously
this is not the final end-all be-all and the whole point is to get the input so I
appreciate that thank you David kind of a nitpicky point but I think
important the from what I recall institutions they are seeking
accreditation have to have enrolled students before they can even get to
candidacy great I’m sorry any institutions seeking
accreditation have to enroll students even before they can get to candidacy
usually for an institution there are some programmatics that in which they
provide pre pre candidacy are I’m sorry pre accreditation or candidacy on the
basis of a plan for like a program so yet again this is what this pre
accreditation definition would apply to not just institutional creditors but
programmatic as well so it’s not always the case that there are students that
are enrolled before they were to be granted for accreditation okay but let’s
take the case where they are enrolled and let’s imagine that the institution
has an expedited process for getting students through like some
competency-based programs do you it’s easily conceivable that the institution
will that the student will graduate before the institution gets to pre
accreditation status you mean gets to accredited status right
okay and in that case the student has graduated from an unaccredited
institution and I’m wondering if there are to be some provision to grandfather
those students and so that they can say that they graduated from accredited
schools because when they’re applying for grad school this is particularly
important at the undergraduate level then they are penalized for having
graduated from an institution where they you know it might be a perfectly good
school right okay I appreciate that I know that that’s an area that the
administration has been interested in so I’m happy to take that back as adding
that potentially to this section as well merit II
I just have a quick question I’m not an expert in this field but I assume if
they could keep it noticed for the remainder of the term but perhaps an
additional term to get to Jessica’s point is it is there a stipulation
somewhere in the language that says they can not admit any new students or cannot
take new students into the program that’s an excellent point I think that
we should take that back as well yeah I would take that back Julia
Thanks I just have a couple questions so this is pre pre accreditation sometimes
referred to as candidacy status but that hadn’t been defined previously is that
correct consent like this is a replacement for a definition of
candidates no it’s a common term used among the accreditation community okay
can you give more context to the rationale behind this addition and
especially I’d like to understand as you all were y’all we’re crafting this
language if there’s conversation around it what sort of if this creates some
sort of risk and how you’ve quantified what that risk is I just curious I don’t
think that we have any I don’t have any data sources to pull of any anecdotal I
think what it I think it’s just this was trying to provide protections to
students that you know they went in assuming that their institution was pre
accredited and that would stay that way and then would I mean the point is that
we the expectation is likely to attain a full term of accreditation before the
expiration and for whatever the reason is whether the institution failed to or
program failed to meet the standards or the time expired that this was seen as a
protection to the students of being able to hopefully disrupt as little as
possible the studies of those students and then be able to provide protections
to them to not lose aid to not just have it just be a very large as was these
used before chaos for them thank you I felt very strongly that the
best thing for students and failing schools isn’t to stay in the failing
school you know sure you can get some more credits you can finish the term
let’s imagine this is a programmatic accreditor and it’s something like
ultrasound tech you know that’s what we see a lot of people in if the state
licensure won’t accept those credits it’s not moving the ball any further I
think you know at this higher level this conversation is going to come up and
again and again and it’s a few different kinds of regulation regulations we have
and from the position that I see my clients and at each out if done
exceedingly well is occasionally a good option an option that’s really good for
people is closable discharge and I know that that can be expensive and maybe
that you know is a rationale for not wanting to have it but I would much
rather have like tighter regulation on the front end to avoid sending a bunch
of title for funds to schools that are going to close then to have the
department worried about spending all the money on clothes will discharge
ensue I think you know I would have serious
concerns about protecting students by trying to keep them in schools that
aren’t really succeeding for them I just I don’t it might be like three months of
gain for like a lifetime of loss you know when you’re a when you’re thinking
about it that way it’s um more debt and I don’t I don’t see that as positive David did you have something to say okay
Jodi I was just wondering if given some of these concerns whether people would
be interested in suggesting deletion of number two in the definition of pre
accreditation I’m happy to take that proposal back I
mean from the committee I mean you can conclude that within your minutes but
I’m also happy to take that back so the it’s been proposed that we
recommend deletion of number two so whoever’s taking a moment to read those
if you get let to get an idea of how how you all feel about that do a vote of
thumbs and see see how you how you feel about that so it’s go see a thumbs up
sideways or down thank you leah did you have a comment so if we’re
gonna take out the ability for students to have ade through the end of their
enrollment contract maybe another provision that could be
added or or discussed Beth is you know institutions and pre accreditation
status you know that are not certain what’s gonna happen
should have a good teach out strategy right that’s reviewed by the accreditor
potentially the state other potential partners um I mean it at our accrediting
organization we require every school to have a teacher across the spectrum all
the time and it has to be updated regularly because you never know what’s
gonna happen especially in distance ed you just you just never know what could
in fact a learning system if it comes crashing down
who knows I just I really think that this conversation about the pre
accredited status and the uncertainty for the students could be addressed
through teach out thank you Judy yeah I would support the addition of such a
such provisions well so I think yep there’s no other discussion on this then
yeah I think we can we can move on Thanks thanks to everybody just as a
quick aside I don’t plan to just run out of here if there are other questions
going forward I’ll be happy to answer them and as things come up related to
accreditation I’m happy to answer those as well thank you I just want to
formally thank Beth for all of her help today and I don’t think without her we
would have been able to get newly this far so again my sincere appreciation
right now we’re going to move on to the definition of distance education and
David will believe that discussion all right yes skal hold on a second now
we have let’s go off like a five-minute break Gregg are we good Scott was just asking
if we have a contact list for all of you and I believe I do we had all your
contact information so if as long as those emails are good and you don’t mind
being contacted in the way you initially told us you wanted to be contacted than
anything we send to you we’ll go to those email addresses okay I’m going to
turn the discussion over to David all right all right so we’re gonna move on
to what is clearly everyone’s favorite topic of the day this is the definition
of distance education so we we all as you guys are know we already touched on
this a little bit in our discussion of the definition of correspondence course
and we can certainly look back at that definition as we talk through this as I
mentioned before distance education is defined in statute and to differentiate
courses that have that use certain kinds of technologies and that are designed to
support what what the statute says is regular and substant interaction between
the students and the instructor as some context the department in 2014
published a Dear Colleague letter that addressed this topic and it was the
first time the department had had published substantive guidance on this
topic in that guidance the department indicated that an institution could have
a an academic model that involved multiple instructors and a disaggregated
faculty model the Dear Colleague letter went on to say that that the fact the
personnel with whom students interact have to meet accrediting agency
standards for instruction and the subject matter under discussion so that
Dear Colleague letter is the current guidance for what constitutes distance
education this the changes that are that you’ll see here and I’ll go through them
specifically but in general they’re designed to number one clearly states
show that it can be more than one instructor with whom a student interacts
to meet this requirement number two establish that members of an
instructional team can qualify even if they have roles that are not necessarily
what we might traditionally call a quote unquote instructor and then number three
and more substantively probably and again I’m sorry for using that term when
you if you scroll down we also created much more robust definitions for the
concepts of regular and and substantive which we’ll get into in just a second
and finally we pose here that the the distance education definition is going
is actually composed by the institutions accrediting agency rather than the
department and that’s the fight the last and final component to what the
department is proposing here so before I get into the details let me pause there
and see if you guys have questions about that kind of sort of conceptual
framework okay so that is what the department had in
mind as weak as we constructed this definition one thing I want to be clear
about as we move down into the the language that actually defines the
concepts of regular and substantive is that the department can say the
department came up with this as a floor as sort of a set of things that that we
that we think could be defined as regular or substantive but again because
we are deferring this definition to an accredited accrediting agency the
accreditor could choose to use all of these things or or potentially have a
different concept as long as it fits somewhere within this definition that
this that is established here so I’m gonna go through now what we mean by
regular and substantive and I’ll just go ahead and read those to you guys and we
can talk through them so first under 2 we have concept of regular and the
proposed language is regular means the frequency or period periodicity of
contact that is romanette one initiated by a person or group of people as
described in paragraph 3 roman at 1 of this definition other than the student 2
covers the students period of engagement with the course with a frequency and
periodicity different determined by the accrediting agency and must cover the
period of time prior to the students completion of all required assignments
or demonstration of competency 3 the required frequency and periodicity may
differ based on the needs of individual programs and for regular means frequency
of contact that is at least once per week for a non term program and at least
equal to the number of weeks in the term for a term based program yep I’ll pause
there because we may have some comments about regular so 4 seems to go directly
against so once a week but then everything else is however often the
institution and the and the accredited to say yes keeping in mind that this is
all just proposed lang it’s not something that we consider to
be final but what what it says is that the accrediting agency and the
institution can decide on how often it needs to happen but it has to happen no
less than once per week so I have it more than once per week and that could
be a requirement established but it has to be at least once per week that’s what
the language here says Julien we and we recognized that a lot of this needs
quite a bit of editing before we get to the final product yeah yeah sorry if I
missed my opportunity to say this earlier I thought you were going through
the whole page but I misheard what you said so just back to what you said about
the first part where you’re dealing with the definition of distance education as
it is I am confused about the definition and I get this gets to later in the page
a little bit but do we need to regulate on what members of an instructional team
like what does that mean what is the definition of that and I get it says it
later but then the definition later actually makes it suggest that you could
have an instructional team that doesn’t have any actual faculty on it so that I
have per my earlier comments of concerns about providing a pathway where there’s
not actually any faculty and then I’m I would love to hear from your legal
counsel at the table about rewriting the definition of distance education even
though its statutory I just don’t understand how this works because I
understand that there’s a distance education and definition in HEA but it
looks like we’re changing it slightly here especially I think we’re expanding
on it like more is it more application interpretation of it so because I have
the statutory definition right here we pretty much just say regular and
substantive without ever defining what regular and substance to mean which has
gotten into some issues with enforcement compliance and all that kind of stuff so
I think this is given some parameters to those so I understand I’m not concerned
about that part actually I just am asking with respect like it feels like a
substantive change to we needed like a different word for that cause something
else we’re gonna find one for talking about adding the addition of or
members of an instructional team I don’t think that’s I think in on the
department’s viewing that as an expansion on the term instructor now if
you have views on that we’re happy to take them back with that is to allow I
think some of the new areas that people have been dealing with where they have
instructional teams they have academic coaches and things like that so they’re
trying to get past the what the traditional definition of you see your
physical science instructor in front of you it’s not just that instructor there
may be other components as in I guess the traditional school would have your
TAS or something like that so that there are institutions that have models where
they have instructional teams versus just one instructor with the substance
substantive subject I should say subject matter
instead of substitute to matter so I get that so Capel university has our flex
path model which uses instructional teams so I get it we’re in favor of that
I think we just want to make sure that I would love to hear robust conversation
about how it is we recommend defining an instructional team because from my
perspective providing a pathway where an instructional team doesn’t actually have
to have subject matter knowledge or a faculty which is how I’m understanding
the bottom half this page sorry I’m skipping ahead feels problematic so just
just to clarify we are interested in the views of the committee about what kinds
of things are need to be in place for an instructional team to meet the
definition here so we’re interested in all of your suggestions about that Russell Russell thank you yeah this is a this is a tough
one you completely understand that we have this statutory requirement in terms
of the correspondence versus versus distance education and I guess one of
the problems we’ve had with this is that doing something that is very
prescriptive in terms of putting these sorts of things out here absence of any
outcomes has been a been a problem for CBE and distance education institutions
where it’s it’s just we’re looking at just what you’re doing not that okay I
broke one or two of these but yet students are still learning and so
that’s a bit of a problem not sure how to fix that at the moment but looking at
your your language here I guess the other part of it first thank you for
actually you know doing more to define this has been probably done in a long
time the problem I always have with regular and substantive interaction is
that including this everything I’ve ever seen talks about regular and substantive
instruction that’s really what this is because it’s the it’s the the faculty is
the person or the group of people group of faculty are the ones that are doing
it and so when we get into CBE and we’re going to have to have some ability
within CBE for some sort of interaction where it’s actually the student who is
doing it and I know that starts getting Paris perilously close to correspondents
but we need to figure out a way where a student can initiate the interaction and
that there’s a some sort of idea about it there’s quick turnaround on that it’s
not like correspondence where it could take take whatever that it’s a an issue
in the CBE world the other one I had any institution call me about number two
robinette for down here and saying that the at least once per week for a CBE
program ends up being a problem because they sometimes have they they could they
have sometimes have students who are and like in my definition and your regular
schedule because they’re on CBE so they could do things where they
follow up with them every week and that might be good but it
has a feeling of make work or make do but there are but there may be something
where if there’s a planned outage especially like in subscription programs
or something like that that where we know the student and the student and
their mentor have planned not to interact for a three or four week period
that that would be that would be allowed as long as it’s part of some plan or
that there’s it’s understood that the the the faculty or the institution or
the mentor is checking in at least to make sure okay are we still on the plan
we’ll be back in three cuz they felt that they needed something a little bit
broader than the ones once per week and I think they was saying this was to lay
out for us for a starting point recognizing that we have the competency
base which is one of the bigger issues in terms of dealing with that in
traditional schools but we also have to keep in mind that we still have to meet
regular which is in the statute so we’re open suggestions on how we do that but
still getting past maybe what Webster’s definition of regular is frequent some
kind of frequency based and it may be different for confidence
competency-based education than the traditional but that’s kind of where we
had came up with a starting point which would look more like a traditional
school with the once-a-week but do we might be able to separate that out yeah
I agree completely and one of the other things that that we’re proposing here
and again all of these are proposals if there’s suggestions about a whole
different direction we’re interested in that if there’s suggestions about the
specific language or interested in that too but one of the things that we’re
proposing here is to give the accrediting agency the ability to have
as much specificity as it wants to about how to define these things and and under
this proposal an accrediting agency for example could say for a competency-based
program regular and substant interaction means this for an on-the-ground program
art so for a traditional program that is you have has regular synchronous
interactions it’s this the point is that we recognize that a one-size-fits-all
solution is very difficult to come by given the different types of modalities
that we’re working and that’s part of the reason for
proposing these changes so we’re looking for something that gives adequate
flexibility to institutions and potentially to accrediting agencies if
they’re the ones that will do these definitions to come up with something
that works for people while still meeting the letter of the wall which we
have to do we can go ahead and now so I think Jessica Jessica headed up and then
you part it down so I’m gonna I recognize you then it’s Amanda okay
could you send us that Dear Colleague letter and maybe a blanket request for
any time there Dear Colleague letters that are relevant to what we’re talking
about to Sonoma if you can well I think it’s best if I send a link to their
colleague I mean I don’t say any reason to put it in the in a PDF I wasn’t send
you the link to it you can click on it and go retrieve it from it’ll be a link
to I fat but yes I can we can definitely send you the links to any dear colleague
letters we reference thank you just briefly I would also agree I think with
some of the instructor questions you brought up and I am guessing this might
be where merit II would be going but I I think like again with an accreditor a
race to the bottom if creditors are the ones defining what regular and
substitute interaction means an institution that wants to provide the
lowest level could go searching for an accreditor that would permit them to do
so Denise did you want to speak okay I give you a little precedence you know
okay Amanda go ahead so in the spirit of protecting quality of education
especially in higher ed knowing that dis in distance education students are more
at risk they’re isolated more so from resources so I understand like the
concept of instructional members I’m weary and questioning of them I don’t
like that the language says instructor or members of an instructional team
because to me I’m not a lawyer but to me that says it could be an instructor
that’s not that is qualified has a master’s program
is it’s a subject matter expert which I would want to pay for that’s the
knowledge I’m gaining I’m gaining resources and their background and their
experiences when I’m paying for an education I’d want a subject matter
expert that’s gonna give me the skills to work in the workforce be hired by
employers it is it’s what makes higher education worth it but to have or as
that says that to me it’s like well we can choose to provide if I’m an
institution I could choose to provide a subject matter expert or an
instructional team which may or may not be subject matter experts they may be
surface level experts maybe not experts at all so that’s that’s very dangerous
that’s dangerous to me I would rather have I would want to make sure and
protect students especially knowing that they’re more risk averse and these
programs to make sure that they’re provided and protected with the bare
minimum should be a subject matter expert for effect instructional teams
that’s an interesting concept and I think I don’t that’s a separate
conversation I think that needs to be hashed out more but definitely has a
standard federal standard subject matter expert would be you really need to be
clarified and protected I believe Mara Dee’s next yeah I I
encourage us to be careful with the term faculty because different states
different unions that term can hold a lot that we in this room may not get our
arms around so I think we need to be careful when we use that particular term
I’m in favor of the instructional teams because I do think in many places we
have it broken out we’re different people and we use the example of a
traditional institution where GA may provide a lot of the a lot of the work
and/or the grading and you still have an instructor of record I do think we could
work on the language to ensure that that instructional team that a member of that
at least one member is a subject matter expert and so we could break out the
role and clarify that we don’t lose that
expertise and then leave it to the institutions to decide how that you know
like I said you may have somebody facilitating tutoring you may have
somebody assigning grades and somebody creating the material somebody has a
discussant etc okay I’ll take that I’ll take that idea back okay
I believe it’s Lea so I’m looking at these words as determined by the
accrediting agency and I’m thinking about as I’ve mentioned a lot of
different accreditors our gatekeepers a lot of creditors might define this in
different ways that could have implications for students I’m wondering
if there’s you know any way we could put just a little bit of scaffolding around
this and maybe it’s through the recognition criteria for creditors I
think we probably want to stage something there if we’re gonna put you
know this kind of responsibility on a creditors to determine what is
appropriate number of times qualified faculty interact with students over the
course of learning I also think that regular has to be looked at in the
context of the types of interactions from the substantive piece because you
can have lots of regular contact that that’s nothing for the student if it’s
really if it’s not good quality engagement do you know what school can
document the heck out of doing things once a week but if the accreditor you
know doesn’t have a good process in place to kind of look at what’s going on
between students and faculty you know then we’re probably not going to see
outcomes being that and those types of things so I don’t have a suggestion for
you David on what to put there but but it is giving me a great deal of pause as
determined and maybe language like as assessed as evaluated as verified might
be stronger well let me can I ask a quick question about your first proposal
so the concept with this language as you’re reading it is that these are the
general requirements for what the accrediting how the accrediting agency
defines it but I think you were suggesting something else about
the recognition criteria if you have thoughts about that you can let us know
but I think that is that something that you know we can look at right the
recognition criteria is basically silent on how a creditors deal with regular
hope some interaction doesn’t say anything it says a creditors have a
process for reviewing distance ed as standards for viewing distance ed but it
never touches on the gatekeeping role of regular and substantive so you’re right
the current law doesn’t doesn’t indicate that in the proposed language that we
have that was discussed during the main committee we did include and it’s not me
it may not be as robust as what you just described but we have a paragraph that
indicates that they need to have a definition of distance education and
correspondence that is sufficient to distinguish between the two and that
relies on the on this definition as again as the sort of foundation for how
it works but there could be other things that that that we would want to look at
and weren’t like I said we’re interested in that if you think it’s gonna be that
would be helpful I just add having a definition and having a robust
assessment of how that definition is implemented okay David in just a
language suggestion for you David under the regular section I would after number
one take out two and three and at the end of four just as it just add or more
frequently as determined by the accrediting agency because that’s really
what what you’re saying and then you can abbreviate it can you repeat that he’s gonna write it
down Julian did you ever come in okay that’s
probably intentional I agree with the comment about let’s think about how we
can better define an instructional team to make sure it includes and I know I
used the word faculty sloppy so I’m sorry I don’t have a better word for
that I get the nuances especially from differences and accrediting agencies and
such but just to make sure that we’re representing that there needs to be
subject matter expertise represented in that term and I have a couple comments
on substantive but I don’t know if you want me to wait until is there is there
anything else on regular because I’d be glad to move on if we yeah okay actually
and I feel funny because I’m like aligning with different people depends
on how it goes so sorry David I’m breaking off with you I struggle with
this language a little bit because I think the accreditors are going to look
at it in some ways say or certain accreditors will say well obviously we
should be more can more frequent than weekly because they stuck that in is the
expectation I think it does not hit Russell’s point of view that some
students are some programs may be planned to be less less frequent than
weekly my concern is that in those it has to be it has to be planned and
determined with the student and what is less weekly it’s not you can’t retrofit
that when the creditors come knocking at your door it’s right I like striking two
and three I just think I’m four instead of saying or more frequently as
determined by accrediting agencies I would say you know or at a frequency
determined by accrediting agencies based on something along the lines based on a
predetermined plan with the student or something so so it’s understood that
because we’re doing this type of program there may be a period of three weeks
where nothing happens at least not an interactive but it is planned it is
programmed out and sorry I’m trying to get them both together that
be more frequent and occasionally it could be less frequent once we gut tells
me that’s probably about right but there’d be a plant there’d be a way for
that so okay they just say or frequency as determined by the accrediting agency so I get what you’re saying I’m super
sympathetic to it because our programs we use subscription pricing and it is
sort of self-paced and everybody hates that term but but I also want to make
sure so to your comment earlier us about CBE programs totally aligned I think we
have to keep checking ourselves the inspect we don’t have a CBE definition
right so this we have to think about this in the context of all distance ed
and so suggesting that a student that we think students can be successful hearing
from their institution less than one time a week makes me just a little
nervous because I don’t I’m not sure I’m not sure I don’t know what the right
frequency is but students are making a huge investment in their education and I
want to make sure that we’re not saying the schools a no the student anything in
terms of providing instruction to that student and at least a weekly basis out
of the answer but I just wanna throw it out there is from a student success
perspective and a completion perspective I want to make sure we’re giving
students what we owe them to so that’s not like other comment I’m regular I
think if there if we can figure out a pathway to provide and flexibility in
those instances were you know these students have it happenss our school to
where students say I’m not gonna be here for two weeks or whatever but it’s I’d
be careful against creating a blanket way to do that I think Russell
if it well Thank You meryt about it I think we probably have to do some word
smithing here I agree with that but I think the having something where it’s
planned and I think because I’m trying to get away from exactly what you’re
talking about to where it’s just the institution just does this has the
openness to do whatever it wants because what you’re describing to me is a as
opposed to what I’m envisioning is that it’s the institution that unilaterally
says that they’re going to do things like take spring breaks oh no wait they
do that so that won’t fit you can’t have a spring breaks anymore so any any way
that we it seems like there’s it’s not the institution that’s determining it
that if we have a plan or agreement or something in there or where it’s it’s
agreed upon by the institution and the student after something that we could
that we could come up with that allows some flexibility I’d like to see that
also on a different topic that I don’t have the exact wording but I think
something about having the the subject matter expert for the course being part
of number one may never open and I might be it might be something to consider
adding as well I’d be curious to hear from you Leah about how equipped you
feel crediting agencies would be to do what’s suggested in that writing now on
a predetermined plan between the accrediting agency and the institution we’re talking about learning settings
that are often highly individualized for the student especially if we’re getting
into flexible paced competency-based direct assessment I just I don’t know if
we’re going to solve for all of those different situations in this language
here and maybe what we need to do is have the rest of the conversations about
direct assessment subscription competency-based all of those other
things and maybe come back to this after we’ve kind of hashed through all of that
and maybe we’ll be in a better place to say okay overarching kind of call on
distance ed is this thing and then we have a stair step for the other kinds of
teaching and learning that we see in distance ed David well just want to pose
one one question to the group going back to our earlier conversation about the
credit hour in which David suggested that the concept of regular and
substantive interaction is connected to it is there do you guys have if we would
be interested in suggestions about tying the frequency to the concept of credit
hours to if that if you guys think that could be helpful because part of the
purpose of the credit hour and the title for rules is to establish an intensity
of of education over a period of time because that’s how we determine the
proration of title for aid so that could be another route route but you know
we’re interested in your thoughts about that Denise so I mean it’s just some of
these things we can think about this about dealing with the competency-based
in context of the language we have a little bit of time and then we’ll have
another meeting together to come up with the language so like Leah said we might
be able to go back look at the rest of the stuff then come back maybe and deal
with the language instead of trying to do it piecemeal it might make more sense
if I just wanna clarify though based on that comment but there’s not a hook your
your language there’s not a hook for a definition for CBE correct I mean I’m
assuming you all thought about that as one option of something you would be
nine I need to go back and look okay again because it I’m looking I’m dealing
with this more in the compliance end cuz that’s the area that I deal with is the
enforcement compliance and so I want to talk to some of my colleagues and to see
what we think in terms of a hook for that Manti I just I’m sorry I point out one
I’m not suggesting it’s not my place to say with what you adopt them what you
don’t but I I just throw throwing this out there so we currently have at least
once under regular at least once per week for a non term program at least
equal to the number of weeks in a term for a term based program so the
limitations that I think Russell is talking about don’t really come into
play with term because it’s just there’s a number but does it have to be every
week so could we consider is there a compelling reason that we all see why we
couldn’t loosen up at least once per week for non term and keep the same
standard as we have for for term base that was equal to the number of weeks so
that we establish some floor for for for a number of interactions but allowing
for the fact that in some the cases of some students it might not be every week
subscribe definition of how long a non term because non term works a lot now
what self with self-paced program so I don’t know as an institution how many
times I’ve just reached out to my student if we do that because it could
take them three weeks or could take them thirty weeks that’s that’s a very good
point it depending upon their pace it could take a long time I mean oh you
could go on you could go on published length of the program right I mean yes
it could take a very number of times but you still do have a published length of
the program and a number of terms trying to find a way we can get around we can
get to accommodating where Russell’s talking about what to think is a real
real need and and and but not just taking away a standard completely saying
well cuz if we say well at least once per week except when you don’t want to
do once per week that I think might be a little loose I’m trying to find a way to
to balance both of those you you can see what we’ve what we’ve proposed here
includes basically a connection to the period of time in which the student is
undergoing the instruction and I just mentioned as other possibility also
including the concept of the credit hour because that reflects the intensity of
the of the instruction so if you’re taking three credit hours over 15 weeks
you might not expect the student to interact as often as you would have
student someone was taking 18 credit hours over the same period of 15 weeks
so again we’re in the published length of the
program as Greg just mentioned is another way that we could potentially
come up with a regularity concept but we’re interested in any thoughts that
you guys have about how to come up with something that is applicable in most
cases and the accreditor can work with but that isn’t too restrictive and and
doesn’t prohibit certain kinds of modalities from functioning so again we
don’t need this happen today but this has been a really helpful discussion I
think for us because it’s kind of brought up some some ways that this
might this might work and we’re interested in hearing more about that
Amanda so for at least I can I just want to suggest or support the language of
the minimum standard that is suggested which is like at least once a week and
yeah I just I like that I support that just that federal minimum standard that
at least once a week then on term yeah the non term thing I can’t cannot I will
not say anything more about that but I just wanted to support the first end at
least nerdy I hope we like we save this when we come back remember where we were
my I like the once a week to with the exception and I actually I then I like
the predetermined plan particularly we’re a heavily military serving
institution and that falls apart in some points but I think if you are going to
serve those populations I think having an agreement with your accrediting
agency on how you do that and what the expectations are I guess I think is
valid rather than just saying we think we’re going to serve this population
I think Jessica’s next I just want to reiterate maybe ideally
more clearly the process point that I tried to make this morning I’m now
understanding that sort of there’s a bucket of making accreditation more
competitive over here and a lot of people have articulated that sort of an
conflict with the bucket we’ve been talking about today about sort of moving
around the rules for distance IDI and CBE and we’re thinking about things like
credit hour and o’clock hour and how those impact distance at on the one hand
a brick-and-mortar on the other hand and we just none of us have I I just don’t
understand what people’s visions are in the room anybody and I I would think
that that might help instead of starting at the red line of what is connected to
what and like what is the world that you want to see with our brick and mortars
regulated like this inside or no and if you have CBE and each are they different
or the same so um I mean IDI I don’t I don’t know if you could provide some of
that for us or next time maybe I’m I’m not sure how to in a good time I mean I
can start and maybe Denise or David can help me here but I from the department
standpoint from what you know what we’re trying to do the vision here so if
you’re going with the the the the current definition of distance education
I think too that it’s you have this definition of distance education it’s
fairly narrow and tying it to I mean it’s it’s distance education but but in
a sense ties it to a brick and mortar type of operation and and doesn’t take
into account the like modalities it’s a new word for me to use now I’ll drop
synergies and use that one but but but it’s a bit all kidding aside it’s useful
in that you know this this proposed language as you see here accommodates to
a greater extent I think where the where education in the distance mode is it’s
not necessarily you know linked to that that single instructor having that
interaction with with that student so you can see here that we went to
instructional team or members of instructional team it
provides a little more latitude for for programs to get out to go outside of
that of that what was formed was currently a fairly narrow box I think
that’s really where we’re coming from with it again it’s a floor we throw out
there to have you comment on but I think that’s the that’s the driving that’s the
driving force behind it I think I think that’s right Greg and so you know the
department is really looking to ensure that students can be served by a variety
of institutions offering a variety of different programs that address students
needs in different ways and you can see this play out in the accreditation part
of the rules as we’re trying to make it a little easier for new accrediting
agencies to come up and to that might be able to address different kinds of
programs you see it in these rules as we’re trying to accommodate for example
clock our programs that use distance education and we’re trying to
accommodate the concept of distance education as it applies in in in that
sector so all of these things are designed to try to allow for new and
innovative types of education that can serve students needs well remembering
that the last part is important we we don’t want to simply throw open the
doors but we we do want to find ways of bringing in kind of types of programs
that potentially don’t exist in a reasonable way I’ve got five placards up
at the moment oh all right make me a liar
you you you out no I so all right now I want to have several I was going to
suggest that we go to three Greg and then take a 15-minute break and then
whoever hasn’t been recognized we’ll start from there all right but that said
I’ve Russ are you going to be recognized because you are going to be next go ahead darn I was hoping going to
break do you think well I was trying to work on something to try to tease out it
seems like we’re now getting a whole lot of ideas into that what is now romanette
ii in terms of term and on term so I was playing here we’re trying to come up
with something where you try to break out for a term that’s at least once a
week and for the non term I still would like to see something where and I was
thinking more rather than that it had to be approved between the accrediting
agency in the institution that it was a student institution agreement you know
maybe that format is approved by the accreditation agency in the institution
but we see those sorts of things that are reviewed by financial aid over time
where you know there’s differences among the students that the institution is
able to do when that there’d be some allowance allowance for that therefore
it’s not the Institute backed what I said before it’s not the institution
implemented it’s only when the institution is meeting a student’s needs
and so I was trying to play with some wording here and we got it done yet as an institution that has a and also
has a very large population of military students I’m very sensitive to to that
population and I go back to because I’m one of those non-traditional learners
that got my bachelor’s degree when I was thirty years old with two kids and
working a full-time job so I don’t want to see us lose sight of what
non-traditional means and at the same time obviously we want to have an
academic program that has obviously you know meets the requirements of the
accrediting agency and at our institution just to say we do have
shared governance and we have someone who you know our Council of faculty to
step in and say this program has to be delivered this way and that is their job
and I want that to be their job I don’t want that to be financially to have any
part of that however I don’t want to see us I’m gonna use my mother’s language
throw the baby out with the bathwater and put something in language that’s
going to be very hard to apply to a population such as the military or other
online students I think that by saying it has to be every week or every you
know twice a week because you’re only an eight week program or whatever the case
may be could cause some problems down the road for those again non-traditional
students I use that and I know it’s probably not the latest buzzword but
like modality Greg I’m not sure about that one but I’m just saying I think
that we can’t we just can’t lose sight of that when we’re doing this this
definition I don’t want to see us put it so strict that then it becomes something
that once again those of us have been innate a very very long time we’ll have
a hard time interpreting the regulation we’ll have a hard time saying yes this
meets this definition thank you carol has something to say but you I was just
a little confused because it seemed like to thank you was maybe modifying the
wrong part I wasn’t I think it might just be a wordsmithing issue because it
doesn’t totally do what we had talked about it may be doing the way it is
perfect Thanks and then Lia oh we’re just hung up on
weeks right we just can’t benchmark against anything
except a week and you had said David what else is there I mean because that’s
how we award financial aid is in these chunks of time and and I guess is there
a way we could consider benchmarking against student accomplishments along
the way as reviewed and and assessed by the accreditor that could be applied at
any learning setting not just distance ed but it seems like our huge hang-up
here is for some reason there’s something magical about seven days and
somehow that’s tied to how students learn and interact with faculty and go
go along there they’re learning they’re learning continuum so I was just
wondering if we could play with some language around that idea could you
could you repeat really quickly what what you just said that the language as
he said something about student I I said you know instead of benchmarking against
weeks you know we benchmark against assessment of student you know learning
and accomplishments along the continuum of their you know program of study or or
their course at that time yes so there are the accreditor has assessed the
intervals along that learning continuum you know that those are appropriate
points to to do an assessment that it’s being evaluated appropriately by the
right qualified people and so we’re using benchmarking in terms of student
learning and not at a week thank you Denise did you know something well no I
just I think the difficulty were having and is the statute says regular regular
its intervals and so I think the easiest thing for the department was and
intervals the week can also be a unit of learning right so I mean I think all
this is good for us to take that but just an recognizing that we got to stick
within the parameters of the stats well difficult trying to match something
that was written a long time ago with the new modalities that we have well and
this is because of the fact that I’ve been eating too much sugar but Greg and
and Denise will remember that we had an assistant secretary once set like the
word fortnight and I think that would be a very pissy idea right so Gillian so I
think this is a good time to stop and when we come back we’ll start talking
about substantive since we were only halfway through now so why don’t we take
a 15-minute break there and I’m just going to splurge and say come back at
ten after you you you you you you you you you you you you you you you together now I’m gonna defer to Scott
first I just have some housekeeping announcements as we’re going into the
afternoon session the first is I’m passing around to everybody contact
information for the subcommittee as well as all the main committees as well so
feel free to take one it probably has Carolyn’s on here if you
had a previous one from yesterday it would not have had hers but for me this
is the first time I’ve had it so I have been unable to forward that Dear
Colleague letter until this point which I will do once we finish with today’s
meeting second item at the end of the day please
remember to leave your badges and your nametags here or your name plates here
we will take care of those for tomorrow if there is any type of inclement
weather tomorrow that affects our starting time please check with the OPM
website that’s opm.gov slash status and it will give you the operating status of
the federal government if there is any type of delay it will tell you there we
consider our start time at 90 and here so if it’s a one hour delay we will
start at 10:00 if it’s a two hour delay we will start at 11:00 and if somehow
there’s a blizzard that comes to tonight and we’re all cancelled we will see you
in a month if there is no delay we will start again at nine which is what we
hope will happen and just as we go back during the break Russ emailed me some
language that I have now put up on the screen in the actual word section the
notes on the side just you know are the previous iterations that people
suggested so I didn’t lose those so that’s something for you to be able to
look at as we move back into the content thank you thanks guy all right well
we’ve clearly tackled regular let’s say let’s start talking about substantive
julene did you have something yep all right did you already have your flag
up huh she’s got that placard up already that’s all right
all right so let me go through the definition here so under three
substantive means and the romanette one interactions within a course or program
between a student and instructors or members of instructional teams as
defined in part two of this definition we know that that all needs wordsmithing
but that’s pointing to – under romanette ii under three here and a distance
learning curricula that monitors progress and provides feedback including
through self-paced distance learning where the students progress is evaluated
or competency is assessed and then to here which is just describing what an
instructional team is this may address at least some but maybe not all of the
comments we’ve had before the various members of instructional teams may have
different and complementary roles and qualifications as required by the
accrediting agency such as to share information answer questions provide
direct instruction provide assessment or feedback monitor of student’s academic
progress or provide student support directly related to the students success
in the particular course prominent three general academic advisors or counselors
are not considered to be members of instructional teams for the purpose of
identifying substitute interactions and for a student must be provided with
feedback designed to support his or her learning and success alright I’ll stop
there and turn it over to Gillian and other comments of course okay so I have
a few comments here sorry to be redundant but I just want to point out
again that we we’re not talking in here at all about subject matter expertise so
I think there needs to be an edit somewhere I’m happy to chat through me
what that looks like but I still feel like the way instructional team is
constructed you could either have an instructional team that doesn’t have any
subject matter expertise on it or you could have an institution could have an
instructional team that has somebody that has subject matter expertise in it
but actually never engage that person to interact with students right so I’m
concerned about creating the conditions where it sort of becomes for a show that
a team is created but it’s really just the lowest the least expensive member of
that team that gets tasked with doing the work so I I’d like to see those
things addressed in sort of future iterations of this and the monitor in
romanette one where it says monitors progress and provides feedback
my understanding this to be sort of the only place in this definition where so
okay so before I say that I would say I think this definition actually defines
more interaction than it defines substantive so for whatever that’s worth
I found this to be a strange definition of substantive since it didn’t actually
talk about substantive and related to that monitors progress and provides
feedback seems like a really low floor in terms of what we expect to see from
an instructor I mean I can this sort of we’re only the minimum for an instructor
to do is to grade as a as opposed to providing learning or teaching so I’m
not sure the solution for that but I’d be really careful I’d prefer to see it
not in there at all I guess as opposed to like setting that as a floor because
it feels like a really low minimum and then regarding let’s see Roman at three
generally I can make advisors or counselors you’re not considered to be
members of instructional teams so get what you’re doing here again our flex
path program we use what I would call general academic advisors though I think
my institution would probably try and make the case that they are more than
general academic advisor as we call them a coach so I don’t want to regulate on
the definition of general academic advisors but it also seems like a risky
area in terms of like who is making the call and what a general academic advisor
is because I think my institution maybe would say coaches are not general
academic advisors there’s so much more I would say no they’re probably general
academic advisors that’s a good point now I would I would point out that my
understanding of the purpose of this is to ensure that an academic advisor that
is doing work that really isn’t directly related to the program or the specific
coursework is not considered to be and part of an instructional team whereas
someone who is working with the student with respect to their actual coursework
is but would say I take your point that the concept might inadvertently sweep up
more than we intended it to so we were interested in comments about how we can
avoid that Denise I just wanted a salient so what do your coaches do so in
order to get content yeah so they do all the probably norm
things that an advisor does right like how people register and etc they also
monitor individual students progress and reach out to them if they’re not
engaging on a regular basis they have access to provide the students in terms
of pointing them to resources to help them something like the Writing Center
or even let me provide you with a good time management module etc those are
probably the main things that they do and it’s not it’s not course specific so
this person is a course automatic program follows the program and that’s
what your concerns are yeah I’m concerned about if that’s the
only instructor on an instructional team the students gonna get a really poor
educational experience David I had a question for you really regarding the
subject matter expert am I remembering that there’s something in the at least
in the guidance language about that that’s right in the dick in the 2014
Dear Colleague letter which is Gen 14 – 23 part of what we indicate is necessary
to have someone be classified as an instructor is that and I’m not going to
get the court exactly right but Scott is gonna send this out to you guys is that
the the staff member needs to meet accrediting agency requirements for
instruction and the subject matter under discussion so for example you couldn’t
have someone who is interacting with a student talking about the weather that
wouldn’t count but you also couldn’t have someone who is an English
instructor talking to a student about his calculus homework that doesn’t count
and nor would it count for anyone without any subject matter expertise to
count under under that blanket concept so that’s the that’s the general rule I
think having a one at least one degree higher than the degree that the students
are pursuing we don’t establish that anywhere in our guidance accrediting
agencies sometimes you have that requirement but it’s not something
specific that we established so I’m thinking of a Chelsea but so so maybe
somehow make sure that that type of person is on
a team right so include that person not ever engaging with the student right so
like I can make a team that’s like you and me and you’re the really smart one
and I’m the idiot and I’m the only one communicating with a student yeah my
accounts like my only concern is again so we don’t have double standards
between online and face-to-face in that regard because there are plenty of
institutions that don’t students on to TA

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