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The “policy wonk” level on this post is turned up to 11. You’ve been warned.

If you haven’t seen Amy Laitinen’s excellent piece on the Education Department’s failure to engage with its own sanctioned experiments with competency-based education, check it out. (Admittedly, that may be the least catchy opening line ever.) Laitinen points out that when the DOE opened the door a couple of years ago for colleges and universities to offer degrees based on demonstrated competencies, rather than seat time, a fair number of colleges went for it. But almost none have actually started, because the DOE is taking its sweet time in issuing guidance for how it wants CBE done.

In other words, as an industry, we’re flooring the accelerator and the brake at the same time.

“Guidance” matters in a host of ways. Many of the financial reporting rules to which colleges are subject are based on seat time and credit hours. (For example, FTE’s -- the typical measure of enrollments -- are based on credit hours. How you would determine FTE’s in a CBE program isn’t obvious. “Satisfactory Academic Progress” for financial aid eligibility is based on credits attempted. Without credits, how do you measure that? Prior learning assessment isn’t eligible for financial aid; at what point does PLA stop and CBE start?In the context of CBE, what’s a “full time” student? I could go on…) These may sound picky, and in a way, they are. But if a college isn’t in compliance with the relevant regulations, the financial and legal consequences can be severe. (If you want to watch a CFO’s eyes get really big, sneak up on her and suddenly yell “audit findings!”) So colleges, quite sensibly, are looking for guidance from the DOE on all of those second-level issues. And the DOE isn’t stepping up.

Which raises the obvious question: why not?  

I can think of a few possibilities, but I have to stipulate that none of these is based on any inside knowledge. Anyone with inside knowledge -- Paul LeBlanc, I’m looking at yooouuu…-- is invited to shed light.

  • They’re overwhelmed. They approved the concept of CBE without first thinking through all of the implications for other policies, and now they’re playing catchup. This strikes me as highly likely.  
  • They’re focused more on “gainful employment,” for-profit providers, student loan issues, and, until recently, the effort to produce college ratings. With other things on fire, something like CBE could easily get overshadowed. I consider this possibility entirely compatible with the previous one.
  • They’re stuck in a contradiction. At the very same time that they’re trying to encourage experimentation with moving away from the credit hour in the context of CBE, they’re also clamping down on the credit hour in the context of online teaching. It’s possible to do either, but doing both at the same time requires a level of theoretical hair-splitting far beyond what they’re usually called upon to do. My guess is that an initial rush of enthusiasm quickly gave way to dispirited foot-dragging as they realized that the two emphases can’t coexist.  
  • Their alien overlords in Area 51, in conjunction with the Illuminati and the Trilateral Commission… (You can fill in the rest. I’m not a fan of this one, but any explanation of federal government behavior on the Internet has to include at least one reference to it. Let’s check that box and move on.)

In the best of all reasonably possible worlds, it’s just the first one, and they’re poised to strike.  

In the meantime, though, I’d love to see some thoughtful discussions of questions like the definition of FTE’s or SAP in the context of a competency-based program. I see great potential in hybrid programs, and in breaking down the barriers between prior learning assessment and CBE, but the Feds need to step up. Done right, the breakthroughs in these areas for which CBE is the catalyst could benefit all sorts of programs.

In the meantime, we rev the engine at a full stop. Thanks to Amy Laitinen for connecting the dots.

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