Over at the Brainstorm blog, the Career Education Corporation’s Diane Auer Jones has a lengthy open letter to President Obama deriding the U.S. Department of Education’s stance toward technology and online learning. Unfortunately, the whole thing is so full of distortions and flat out factual errors that it does nothing to help the debate about the proper role for regulation in online learning.
The most relevant sections:
Starting on July 1st of this year, when a student is enrolled in an online course, and she performs the equivalent of walking into class by logging into the electronic classroom portal, the Department of Education will not consider this to be an academically related activity.
The problem is that now the Department of Education is requiring not only that faculty evaluate this work (as do we), but also that institutions save it in electronic archives so that Department of Education officials can look at it, upon request, at a later date. Now bureaucrats who have never taught a class in their life and are unqualified to do so will be making value judgements about what constitutes an academically related activity and what does not. That, Mr. President, is the camel’s nose peeking under the sanctity-of-the-classroom tent.
It will not be long before students in brick-and-mortar classrooms will be required to have clickers in their hands so that they can press the button every 15 minutes to prove they are awake and in the room, and so that a computer can record each time they raise their electronic hand to ask or answer a question. Faculty members will need to preserve thousands of e-mails to show that they interacted with a student, even if he or she missed class on a given day. I guess faculty will be required to keep electronic logs of who visited during office hours, too. All of this so that a student can have the privilege of borrowing money from a taxpayer at interest rates of up to almost 9 percent. (For those who will undoubtedly write comments about loan defaults, I encourage you to do some research first because even when a student defaults—which means he is 90 days late in making a payment—he does repay the loan or the government collects its money by garnishing tax refunds and social security payments).
Auer Jones’ complaint appears to center around the definition of a credit hour contained in the set of final regulations the Department released at the end of October of last year. Here is the definition those regulations provide (emphasis mine):
Credit hour: Except as provided in 34 CFR 668.8(k) and (l), a credit hour is an amount of work represented in intended learning outcomes and verified by evidence of student achievement that is an institutionally established equivalency that reasonably approximates not less than—
(1) One hour of classroom or direct faculty instruction and a minimum of two hours of out of class student work each week for approximately fifteen weeks for one semester or trimester hour of credit, or ten to twelve weeks for one quarter hour of credit, or the equivalent amount of work over a different amount of time; or
(2) At least an equivalent amount of work as required in paragraph (1) of this definition for other academic activities
as established by the institution including laboratory work, internships, practica, studio work, and other academic work leading to the award of credit hours.
That clearly leaves some room for flexibility and is not some hard and fast dictum based solely on seat time. In fact, the Department’s press release notes this too:
Recognizing that “seat time” is not the goal, the final rule allows for equivalent measurement of learning outcomes. It also clarifies that a credit hour is defined solely for federal program purposes, allowing institutions to set their own standards for academic purposes.
But of course the real trick to what the definition means is determined by how it is enforced. This is where Auer Jones’ point comes in about the supposedly extreme steps being taken to verify academic achievement and activity. Here’s what the regulations actually say about how accreditors and state agencies are supposed to verify that schools are meeting the new credit hour definition. (This is the language for accreditors, but it’s essentially the same. Emphasis added.)
(f) Credit-hour policies. The accrediting agency, as part of its review of an institution for initial accreditation or preaccreditation or renewal of accreditation, must conduct an effective review and evaluation of the reliability and accuracy of the institution’s assignment of credit hours.
(1) The accrediting agency meets this requirement if—
(i) It reviews the institution’s—
(A) Policies and procedures for determining the credit hours, as defined in 34 CFR 600.2, that the institution awards for courses and programs; and
(B) The application of the institution’s policies and procedures to its programs and coursework; and
(ii) Makes a reasonable determination of whether the institution’s assignment of credit hours conforms to commonly accepted practice in higher education.
(2) In reviewing and evaluating an institution’s policies and procedures for determining credit hour assignments, an accrediting agency may use sampling or other methods in the evaluation, sufficient to comply with paragraph (f)(1)(i)(B) of this section.
So accreditors are supposed to make sure that credits reasonably conform to the standards outlined, something they already do. And the regulatory language contains a lot of assurances about giving institutional leeway and flexibility to set their own standards–all they have to do is find a way to document learning achievement. Not to mention that accreditation agencies–who will do most of these reviews–employ faculty for their review teams. Noticeably absent is a description of what defines academic activity or achievement or demands to log e-mails.
We’re hopefully at a point where online learning is primed to increase substantially. It’s becoming increasingly common and established at all types of colleges. And that makes it incredibly important that we get this expansion right. Introducing lots of poor options right now would set the movement back, giving it a permanent association of low quality and on-the-cheap education that would make faculty even more resistant to it than they already are. And so we need a way to set some minimum standard of ensuring that students aren’t being ripped off, while also still allowing for innovation and creativity. The proposed definition tries to balance those things while still leaving most of the accountability at the accreditor level. Is it absolutely perfect? Almost certainly not, but it is a start.
I’m completely sympathetic to the idea that as online learning grows we need the proper regulatory environment to encourage both innovation and quality. Achieving that effectively certainly doesn’t entail a federal review of individual classes, which is why the definitions don’t call for that. Even so, we need a real discussion of ways to broach the simultaneous needs of freedom to experiment and regulation to encourage quality. That talk also needs to encompass an understanding of how to give professors the tools to feel involved in this growth, not opponents of it. But what it absolutely doesn’t need are hyperbolic critiques designed to play on fears of big brother.
(On an unrelated note, the description of student loans and default are completely incorrect. It takes at least 270 days before a delinquent borrower is declared to be in default, not 90 days, something that can be seen right on page 2 of the master promissory note. The highest interest rate on a federal student loan is fixed at 7.9 percent, a percentage point lower than the figure listed. Try securing that in the private market with minimal credit history and no collateral. And of course, institutional participation is completely voluntary. If it’s really so onerous a burden, they don’t have to take the federal money…)