Russ Poulin: The Regulatory Landscape is Changing – And There’s No Map of What’s Ahead

The Regulatory Landscape
Is Changing…
And There’s No Map of
What’s Ahead
Open SUNY Summit 2018

wcet.wiche.edu
Russ Poulin
Director, Policy & Analysis
WCET
WCET
is the leader in the
practice, policy, & advocacy of
technology‐enhanced learning in
higher education.
rpoulin@wiche.edu
@RussPoulin

wcet.wiche.edu
Who Are You?
What is your primary role?
 Faculty
 Instructional Design
 Student Services
 Library
 Administration
 Other

wcet.wiche.edu
Agenda
 Higher Education Act Reauthorization
 Regular and Substantive Interaction, WGU
Owes $700M, and What Does that Mean for
You?
 Federal State Authorization – Will They or
Won’t They?
 They Want to Regulate My Assessments?
 Net Neutrality Explained…by Who?

wcet.wiche.edu
Higher Education Act Reauthorization

wcet.wiche.edu
Higher Education Act Reauthorization
https://edworkforce.house.gov/prosper/
https://www.congress.gov/115/bills/hr4508/BILLS‐115hr4508rh.pdf
Chair
Virginia Foxx
HR 4508

wcet.wiche.edu
A Reminder About Bills

wcet.wiche.edu
WGU
https://wcetfrontiers.org/2012/04/20/correspondence‐definition/
https://wcetfrontiers.org/2017/09/22/wgu‐interaction/

wcet.wiche.edu
“We (OIG) did not assess whether the school’s
model was improving educational quality or
expanding access to higher education. We are
not withdrawing our findings or the
corresponding recommendations.”
https://www2.ed.gov/about/offices/list/oig/auditreports/fy2017/a05m0009.pdf

wcet.wiche.edu
“Distance education means education that uses
one or more of the technologies listed in
paragraphs (1) through (4) of this definition to
deliver instruction to students who are
separated from the instructor and to support
regular and substantive interaction between
the students and the instructor, either
synchronously or asynchronously…”
WGU
Regular and Substantive Interaction
ECFR: Title 34, §600.2 http://bit.ly/2DyoMzI

wcet.wiche.edu
WGU: What Counts as “Regular and
Substantive Interaction”?
Interaction must be:
1) Initiated by the instructor.
2) “Regular” and (probably) somewhat
frequent.
3) “Substantive” – of an academic nature.
4) With an instructor that meets accrediting
agency standards.
From a WCET Frontiers analysis by Russ Poulin, WCET, and Van Davis, Blackboard:
https://wcetfrontiers.org/2016/09/30/interpreting‐regular‐and‐substantive‐interaction/

wcet.wiche.edu
What You Should Know…
 Only a problem if more than 50% of your
coursework is declared correspondence.
 OIG who would like to apply the definition
broadly to any innovation…both at a distance
and on‐campus.
 This will require a Congressional fix.
https://wcetfrontiers.org/2017/10/03/the‐oig‐report‐on‐wgu‐part‐2/

wcet.wiche.edu
What Should You Do?
React…But Don’t Overact
 Assess your vulnerabilities.
 Use this as an opportunity to engage in
discussions about quality instruction.
 Alert your government relations team to
support fixes.
https://wcetfrontiers.org/2017/10/03/the‐oig‐report‐on‐wgu‐part‐2/

wcet.wiche.edu
State Authorization Regulations

wcet.wiche.edu
Federal State Authorization Regulation

wcet.wiche.edu
 Demonstrate Compliance
 Recognize Reciprocity
 New “Public” Disclosures
 Note especially for programs leading to
professional licensure
 New “Individualized” Disclosures

wcet.wiche.edu
July 1, 2018
 Will it go into effect?
 If they enforce it…
 …many clarifications needed.
 Regardless…
  State & SARA are in place.

wcet.wiche.edu
Student Identity for Academic Integrity
and Financial Aid Fraud
Chapter 34, 602.17(g): http://bit.ly/2FuHpqc

wcet.wiche.edu
The existing regulation…
(g) Requires institutions that offer distance
education or correspondence education to have
processes in place through which the institution
establishes that the student who registers in a
distance education or correspondence education
course or program is the same student who
participates in and completes the course or
program and receives the academic credit….

wcet.wiche.edu
The agency meets this requirement if it—
(1) Requires institutions to verify the identity of a
student who participates in class or coursework by
using, at the option of the institution, methods such
as—
(i) A secure login and pass code;
(ii) Proctored examinations; and
(iii) New or other technologies and practices that
are effective in verifying student identity; and…

wcet.wiche.edu
(2) Makes clear in writing that institutions must
use processes that protect student privacy and
notify students of any projected additional
student charges associated with the verification
of student identity at the time of registration or
enrollment.

wcet.wiche.edu
https://www2.ed.gov/about/offices/list/oig/auditreports/fy2014/a07l0001.pdf
https://wcetfrontiers.org/2014/02/26/financial‐aid‐fraud/

wcet.wiche.edu
In PROSPER…page 502…
‘‘…in a case in which the instruction delivery model allows
for the separation of the student from the instructor—
…(i) the agency or association requires the institution to
have processes through which the institution establishes
that the student who registers in a course or program is
the same student who participates in, including, to the
extent practicable, testing or other assessment, and
completes the program and receives the academic
credit..”

wcet.wiche.edu
BEWARE OF VENDORS

wcet.wiche.edu
Explaining Net Neutrality

Russ Poulin: The Regulatory Landscape is Changing – And There’s No Map of What’s Ahead

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