Yesterday, the U.S. Department of Education’s Office of Inspector General (OIG) issued a report concluding:
“We concluded that Western Governors University did not comply with the institutional eligibility requirement that limits the percentage of regular students who may enroll in correspondence courses. Therefore, the Department should require the school to return the $712,670,616 in Title IV funds it received from July 1, 2014, through June 30, 2016, and any additional funds it received after June 30, 2016.”
This recommendation is based upon the OIG’s interpretation “regular and substantive interaction.” The phrase appears in Chapter 34, §600.2 of the Department’s definitions of the term “distance education” as a means to delineate it from “correspondence education.” Institutions can grant Title IV aid for only a limited number of correspondence courses.
Western Governors University (WGU) created a webpage describing its position regarding how its leaders feel they complied with the regulations.
Blog Post Series
This is the first in a series of blog posts regarding the OIG’s actions. Today we focus on our history on this issue and on the notion of “interaction.” In a future post (or posts?), we are planning to talk about:
- The notions of “regular” and “substantive,”
- the specific application of “regular and substantive interaction” in the WGU case,
- what that might mean to others offering competency-based education (CBE) and distance education, and
- what you should do about it.
Improving Quality and Access Do Not Matter?
In our initial look at the report, Van Davis (Associate Vice President of Higher Education Research and Policy) and I took particular note of this comment on page 6 of the OIG’s report on WGU:
“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.”
While we will say more about the report in upcoming posts, we felt that saying that it does not matter whether an institution actually serves students well is an astonishing. This is a severely troubling statement.
Departmental Guidance on “Regular and Substantive Interaction”
The interpretation has been difficult. I have been following this issue since I first reviewed findings of an audit report on St. Mary-of-the-Woods College back in 2012. That post consistently remains one of our top viewed posts each year. Last I heard, the recommendations in this report have yet to be resolved. A final resolution for WGU might have a similar fate.
That report was issued five years ago. In the intervening time, the communications from the Department of Education in communicating its expectations on how institutions are supposed to comply have been few and far between. In August, 2016, WCET published a great post by Myk Garn (Assistant Vice Chancellor for New Learning Models with the Board of Regents of the University System of Georgia) on “Why We Need to Stop Using ‘Self-Paced’ in CBE Descriptions.” Because of the minimal guidance, the issues raised by Myk, and my worry that people were relying on the St. Mary-of-the-Woods College blog post as their guidance, Van Davis and I reviewed all the materials we could find. After reviewing “Dear Colleague” letters, the financial aid handbook, and audit reports, we penned the post “Interpreting what is Required for ‘Regular and Substantive Interaction’” in September, 2016 to assist institutional personnel seeking to comply with the regulation.
From the St. Mary-of-the-Woods report to our review last year and culminating with the OIG findings on WGU, OIG interpretations and how it applied those interpretations changed. Many of the essential points remain the same, but important new criteria have been added over time. Van and I were communicating yesterday on some of the criteria applied to WGU and wondered “where did that come from?” We will get into more specifics in a future post.
Bottom line: The Department of Education is usually very clear in stating the criteria and measures that will be used in assuring compliance with federal financial aid laws. This is not the case on this issue.
When is Interaction Not Interaction?
The idea of “regular and substantive interaction” is anchored in a noble goal that we all support. We do not want federal financial aid dollars going to fraudulent educational activities. There were fraudulent correspondence courses in the past in which the instruction was left mainly to the student’s own devices. As a result, severe limitations were placed on the number of correspondence courses that could be included in an institutions financial aid package.
The notion of “interaction” was used as the main line of demarcation between correspondence and distance education. The problem is that the notion of quality academic interaction is not really what is defined in the regulation. In the Department’s definition of “correspondence course”:
“Interaction between the instructor and student is limited, is not regular and substantive, and is primarily initiated by the student. Correspondence courses are typically self-paced.”
The OIG is looking for interaction that is:
- Initiated by the faculty person.
- On a schedule set by the faculty person.
That’s not interaction, that’s dissemination. Both Merriam-Webster and I have a richer view of “interaction” as an activity that is more give and take and not one-way:
The problem with applying that definition to competency-based education is that:
- Interaction with a student is far more frequent than in a traditional course. Ironically, CBE courses are being called correspondence courses (which have almost no interaction) simply because of who initiates much of the activity.
- The student has more control over the schedule for interaction. CBE is popular with adults who need flexibility in their timing. In correspondence education, students were allowed to float on their own with long stretches of inactivity. That does not happen in good CBE instruction as there is frequent contact to make sure that the student is progressing toward his or her goals.
Bottom line: In talking about the high ideals of interaction to the public, the OIG is playing off the Merriam-Webster notion of interaction that is probably resident in most of our minds. Meanwhile, in applying their definition in practice, they are expecting compliance with an historic model of faculty lecture, dissemination, and control. CBE is not someone lecturing for 54 minutes and asking “any questions” in the last minute. That’s not good interaction in any instructional setting, including face-to-face. Such poor interaction is simply not possible in CBE instruction.
What Might Happen?
The OIG is making a recommendation and this is not the final word. From Michael Goldstein (Cooley, LLP):
“The IG’s report and recommendations go to Federal Student Aid, which decides what, if any, action should be taken. (The “if any” is directly from the IG transmittal.) That involves a further, and often lengthy, review process. The ultimate decision authority is the Secretary.”
Lengthy? Remember that the St. Mary-of-the-Woods report was released in 2012.
Watch for more to come in upcoming posts.
Director, Policy & Analysis
WCET – The WICHE Cooperative for Educational Technologies
This year I had the exciting opportunity to coordinate our WCET Awards initiative. The most valuable aspect of this initiative was the chance to learn about the meaningful, student-focused work being done by various institutions and organizations in higher education. The WCET Outstanding Work (WOW) Awards honor member institutions and organizations that develop technology-based solutions to challenging educational needs.
I am pleased to announce the winners of the 2017 WOW awards: University of Central Florida, Blackboard Inc., Oregon State University Ecampus, and Healthcare Learning Innovations, a division of American Sentinel University.
Over the next several weeks, each of these institutions will be featured here on WCET Frontiers.
Today, we welcome Oregon State University Ecampus to discuss their award winning 3D Virtual Microscope. Congratulations to OSU Ecampus and thank you for your work to increase student success!
Enjoy the read and enjoy the day,
~Lindsey Downs, WCETThe Problem: Biology Students Needing Access to Microscopes
It was a fundamental question in search of a much-needed answer: How can distance students taking introductory biology courses online truly learn to operate a microscope without being in a physical laboratory?
The simple answer was that they couldn’t.
Students could buy a compound microscope to use at their homes, but with costs ranging from $50 for the cheapest ones on the market to well over $1,000 for the advanced variety, it was an untenable solution.
They could enroll in a campus-based course at their local college and use its labs. Commuting to and taking a class on campus, however, would further drain adult learners of their most valuable and fleeting resource: time.
The ultimate cost was that the lack of a sufficient, interactive online lab experience delayed and, in some cases, prevented many students from completing their degree requirements.
Those days, thankfully, are over.The Solution: Create a Virtual Microscope
Oregon State University now offers a series of three biology courses online that effectively puts a microscope in the hands of every distance learner. Believed to be the first virtual microscope of its kind, this academic breakthrough is the result of a partnership between OSU’s Department of Integrative Biology, the Department of Botany and Plant Pathology, and Oregon State Ecampus, the university’s online education division.
The groundbreaking lab series recently won a WCET Outstanding Work (WOW) award, given to institutions that “implement exceptionally creative, technology-based solutions to contemporary challenges in higher education.”
It was a significant challenge. But trying to do something that’s never been done before is Oregon State’s comfort zone.Easier Said than Done: Here’s How We Did It
Here’s the Reader’s Digest version of what it took for Oregon State to create the virtual microscope experience and, thus, eliminate a significant barrier to degree completion:
- Six months of research and development
- One year producing a 3-D microscope animation project
- The collaboration of 30-plus OSU faculty, department heads, Ecampus multimedia developers, instructional designers and other staff
Dr. Andrew Bouwma and Dr. Genevieve Weber are the faculty members who piloted the development of the lab series. The end goal was not just to increase access to education but also to make that educational experience rigorous and engaging. The comprehensive development process was necessary to ensure the labs meet the same learning outcomes as OSU’s on-campus labs.
“I teach on-campus and online biology courses, and I wanted to find a way to give my online students the same, meaningful experience my on-campus students receive,” Bouwma said. “I started using the virtual microscope in my online classes immediately, and it’s been an effective tool in my teaching since it allows me to give my students more realistic assignments in cell biology, which I believe improves student engagement.”
The first step in building the virtual microscope was to design a way to replicate the in-person experience in an online, interactive environment. That massive undertaking was tasked to the OSU Ecampus multimedia development team, which pushed the limits of what’s possible in online education.
“I took the exact microscope that the students on campus use, and I measured it down to the millimeter so that I could model the virtual one precisely,” said Ecampus multimedia developer Nick Harper. “Then, using 3-D modeling software, I was able to manipulate basic shapes like cubes and cylinders to build an accurate digital model of a real microscope.”
Then came a year’s worth of animation work, using game development software that would enable students to manipulate all of the microscope’s controls – adjusting the brightness, increasing the zoom, focusing the viewer and so on. The Ecampus staff then mounted a camera on a real microscope and took photos of slides that were central to Bouwma’s instruction and programmed those images to create the virtual simulation.
“Ultimately, we were able to create a solution for students to maneuver a microscope’s settings and adjust the images the same way they would in a face-to-face environment in a lab,” multimedia developer Mike Miller said.It Worked – with Minor Setbacks- and Has Been Expanded
It was a safe bet that the virtual microscope and corresponding online lab courses would be in demand among distance learners, but it has exceeded even Oregon State’s high expectations. Since the series was launched in 2015, OSU has had to add sections for each course in the online series because each one enrolls incredibly quickly.
The virtual experience has not been devoid of hiccups, of course. There have been some challenges with tech support along the way, but luckily the instructors are so familiar with the material and software that they answer questions quickly. Members of the Ecampus multimedia team also have been able to lend a hand when needed.
Oregon State has also added more slides, fine-tuned the virtual microscope’s features as needed. It’s also being used in other Ecampus classes, and it’s been added to the university’s open educational resources (OER) library, giving anyone in the world access to this innovative and, for many, essential tool.Success = Need + Collaboration
“When I describe this project to others, I tell them that this is the kind of collaboration that all others should aspire to,” said Shannon Riggs, the Ecampus director of course development and training.
“Everything was created based on student need, and that really galvanized all the people who worked on the project. It helped us approach the project with enthusiasm and passion – to boost student success and break down barriers to degree completion.”
Marketing Communications Manager
Oregon State University | Extended Campus
If you’re a high school student in rural America, it’s not always easy to get to school. You may have to travel a lot farther than you would in the city. But what if you live in a rural area and also need to travel with your family to go to work on a farm? How would you get to high school? Could you go to college?
The U.S. Department of Education’s (ED) Office of Migrant Education (OME) recognizes the challenges that migrant families face and oversees two competitive grants that provide high school and college opportunity for migrant and seasonal farmworkers. The High School Equivalency Program (HEP) funds selected two-year community colleges, four-year universities, and nonprofit community organizations that provide high school equivalency classes tailored to the needs of these students. The College Assistance Migrant Program (CAMP) grants money to community colleges and universities to offer migrant students their first year of post-secondary education.
“These HEP and CAMP programs change lives for many generations,” said Lisa Ramirez, director of both OME and the Office of School Support and Rural Programs, as well as the daughter of migrant workers and a former migrant worker herself. “To my knowledge, there is no other program that is set up the way HEP and CAMP are set up, and the support activities that we provide to our students are unique.”
Nationwide in 2016, 2,405 migrant and seasonal farmworker students earned a high school equivalency diploma through HEP, and 1,475 migrant and seasonal farmworkers completed their first year of college through CAMP.
This past August, OME held its annual HEP/CAMP Directors Meeting, at ED headquarters. Approximately 130 grantees attended the two-day conference to receive OME technical assistance and collaborate. The agenda featured two student speakers, one of whom graduated under a HEP grant and one who is studying in a CAMP-funded college program.
Students Yolanda Ambrosio Barrientos and Sandra Reyes spoke about their respective experiences in HEP and CAMP. Barrientos arrived in the U.S. without a high school diploma and not speaking English. While a migrant farmworker, she was subjected to violent domestic abuse in her marriage. However, Barrientos persevered and earned her high school equivalency diploma under HEP at Wake Tech Community College in North Carolina.
Reyes overcame performance anxiety and challenges in family relationships while she was a migrant farmworker and is now pursuing college studies under CAMP at Eastern Washington University in the state of Washington.
Maria Fister, director of Wake Tech’s HEP, arranged for Barrientos to speak at the Washington meeting. “Something that makes our program stand out is that we establish a really close connection with the students,” Fister said. “Students make a commitment not only to their personal education goals but to the program.”
“We don’t want students to stop with the high school equivalency. We want them to go to college, to get better employment,” Fister said.
Ramirez explained why having student speakers is important. “The tenor of the students’ speeches reminds us that every day, we’re not just pushing paper; that what we do impacts lives,” she said. “Yolanda’s speech reminded us that not all students are young children and that being a lifelong learner is critical. And someone can survive domestic abuse and still be an English-language learner, and the progress doesn’t stop there.”
Joe Barison is a public affairs specialist with the Office of Communications and Outreach.
Photo at the top: Yolanda Ambrosio Barrientos arrives with her family for her high school equivalency graduation at Wake Tech’s partner school Wayne Community College, where Yolanda attended classes. Wake Tech HEP has collaborations with community colleges across North Carolina (photo credit: Maria Fister).
The post Education Opportunity Migrates to Nation’s Farmworkers appeared first on ED.gov Blog.