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Carolyn Holcroft, Foothill College, Curriculum Committee Member
Michelle Pilati, ASCCC President
Revisiting the Separate Approval Process for Courses Offered Via Distance
Education
Overview
Why separate approval?What criteria should your curriculum
committee be considering?Why regular effective contact?Why is regular effective contact more
important than ever before?
Compliance
Title 5 MandatesSeparate reviewRegular effective contact
Accreditation standardsSection 508 (accessibility)
Financial Aid!
Last Date Of Attendance (LDA)The date an institution is expected to
use to calculate amount of Title IV refund when a student withdraws from a program
The later the LDA the less refund
Last Date Of Attendance (LDA)
How do you certify LDA if you aren’t taking attendance?
What suffices as “taking attendance” in distance education?
Determining LDA/Effective Withdrawal Date
Institution may either use: the mid point of the financial aid ‐
payment period, orit may document the student’s actual
LDA as determined by his or her last known “academically related activity.”
For Distance Ed…
Traditionally we’ve determined LDA based on the last day a student entered a secure classroom site (logging in)
USDOE has taken the position that logging in is NOT sufficient to document student’s LDA in an “academically related activity”
DE/ Last Day of Attendance, aka the R2T4 calculation Federal Guideline issued 2010
Guidance with the new federal regulations requires evidence of “academic engagement” for online enrollments.
..accreditors are supposed to review whether the classes that institutions classify as DE involve active engagement of students; if not, they are to be classified as correspondence education
(ineligible for Title IV aid) and accreditor to review institution’s compliance with Title IV requirements
Implications for DE: Defining Academic Engagement
USDOE has begun retroactively enforcing this heightened standard that requires documentation of “regular and substantive interaction between the students and faculty,” through:
Regular and Substantive Interaction
discussion board posts,completed assignments, or electronic conversations with facultySort of sounds like “regular and
effective contact”, eh?
Ouch-comes?
•Dept. of Ed. Admits that there is NO prior general guidance supporting it’s position
•However, it has retroactively applied the new standard to prior year’s program practices.
•The Ultimate Bad outcome: An audit that finds that your program lacked sufficient engagement and should be classified as “correspondence study” which could make them ineligible to participate in the Title IV Programs.
Michael Goldstein, Dow Lohnes PLLCFriday, October 28, 2011
Classes Held to Different Standards?
So – evidence of “academic engagement” required for online enrollments…
…vs requiring evidence of “physical presence” in the classroom for the face to face programs.
Pre-emptive Solutions?
Make it clear to online teaching faculty that CMS statistics are not enough.
Define and enforce Regular Effective Contact at your college.
Pre-emptive Solutions?
LDA policy is created and enforced that includes academic engagement (activity).
Instructors save work of the student dropped and document when the activity stopped.
Sample LDA Policy—Comments?
When a student has not participated in discussions or other forms of communication and/or has not submitted assignments for two consecutive weeks, the instructor will attempt to contact the student and notify them that they have 5 days to complete the missing work or be dropped from the course.
The instructor will document the student’s work until the point of dropping the student.
What do you mean, “State Authorization”??
October 2010: USDOE released “program integrity” regulations
Institutions offering distance ed or correspondence education need to acquire authorization from any state in which it “operates” Required for students of that state to remain eligible for federal
financial aidInstitutions have until July 1, 2014 to obtain
authorization(s)
http://wcet.wiche.edu/advance/state-approval
USDOE won’t initiate any action to establish repayment of liabilities before July 1, 2014
Evidence of good faith efforts by institutions could include any one or more of the following: Documentation that an institution is developing a distance
education management process for tracking students' place of residence when engaged in distance education
Documentation that an institution has contacted their State directly to discuss programs the institution is providing to students in that State to determine whether authorization is needed.
An application to a State, even if it is not yet approved. Documentation from a State that an application is pending
Issue of State Approval
Steps for now:1.Identify your out of state, online only ,
students2.Check to see what the states involved require3.Get your materials together that meet those
requirements4.Contact the appropriate state regulators to
see what you need to do.
State Approval Resouces
State Higher Education Executive Officers – list of state requirements. http://www.sheeo.org/stateauth/stateauth-home.htm
WCET Resource Page http://wcet.wiche.edu/advance/state-approval
Conference: State Authorization: Managing for Success: http://www.slideshare.net/WCETConference2010/state-authorization101session639
Does your local process for reviewing distance education courses do all that it can – and should – do?
Are your local processes designed to not only ensure that all faculty teach to the course outline of record, but to do all that they can to ensure the integrity of your distance education offerings?
The scrutiny being applied to distance education from others outside our colleges is greater than ever before; is it time to revisit the scrutiny applied by local curriculum processes?
How can your curriculum approval process be improved to not only meet existing Title 5 mandates, but also facilitate student success and increase the quality of your distance education offerings?
What’s next?
Defining the online credit hourThe continuing saga of State ApprovalAcademic IntegrityAccreditation stories