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Arizona State University has yet to brief its accreditor about plans to award credit through massive open online courses to thousands of students at the same time. While the university is unconcerned, accreditation experts are unsure if federal or regional regulations could derail the initiative.

“We weren’t aware of it,” John Hausaman, public information officer for the Higher Learning Commission of the North Central Association of Colleges and Schools, said in an email about the Global Freshman Academy, which ASU announced Wednesday evening.

Hausaman added, “Not to say that they had to notify us, but we will follow up with them to make sure we have a complete picture.”

The new partnership between the flagship public university and edX, a MOOC provider, flips the typical process of getting into college on its head.

Students interested in the MOOCs won’t have to apply and be admitted to Arizona State, but can simply register for the courses. Instead of paying up front for tuition and working to make sure the money was well spent, the MOOC students decide whether or not to pay to earn credit only after they have received their final grades. The risk, apart from spending the seven and a half weeks each course is expected to last, is a $45 fee to verify your identity, a prerequisite to pay for credit.

Despite those details and the fact that a single Global Freshman Academy MOOC could enroll twice as many students as the 13,000 currently pursuing certificates and degrees through ASU Online, the university said it does not “anticipate any issues” with its accreditor.

The Higher Learning Commission on Thursday was not prepared to discuss how its standards may apply to the Global Freshman Academy. “We’ll have to get more information from Arizona State on the matter before being able to discuss its meeting our standards,” Hausaman wrote.

For now, part of the uncertainty has to do with figuring out what the program actually is -- and then how it should be evaluated.

On paper, the commission’s standards suggest that some of ASU’s plans may only require the university to notify the accreditor, while others may require prior approval -- a process that can take three to eight months.

First of all, the sheer numbers themselves may pose an issue. According to the standards, “Significant changes in the character or nature of the student body of the institution” require prior approval. The plan to teach that many students at once may also draw scrutiny. “Instructors are accessible for student inquiry,” one standard reads, but ASU plans to use teams of teaching assistants to field questions on discussion boards.

Perhaps most importantly, the commission requires that an “institution’s program quality and learning goals are consistent across all modes of delivery.”

Philip Regier, university dean for educational initiatives, made that argument in an interview with Inside Higher Ed, saying the MOOCs will be “the same in all essential respects” as the variants of the courses taught in person or through ASU Online.

ASU’s experience with offering online education is likely to simplify the process. Colleges and universities accredited by the commission have to seek prior approval for their first online education programs, but after that, the “HLC no longer requires program-by-program approval of distance education for those institutions.”

Federal regulations add another layer of complications. Based on the details released Wednesday, the Global Freshman Academy in many ways resembles online, competency-based programs. Regier this week used the term “competencies” when referring to what students would be expected to learn in the new courses. And the pathway to accreditation for a related, emerging form of competency-based education, dubbed direct assessment, hasn’t always been smooth.

The U.S. Department of Education’s Office of Inspector General last fall pumped the brakes on new direct assessment degrees. In an audit, the IG raised questions about the faculty role in those programs, asking whether they require “regular and substantive interaction between students and faculty members.” It also said the department had not addressed whether students might receive federal aid for “life experience.”

The IG also audited the Higher Learning Commission over its review of direct assessment programs. As a result, the commission halted approval of new competency-based education degrees. The commission said on its website that it is working to establish “new protocols for review,” which should be finished by May 15.

The Global Freshman Academy will not face the bureaucratic thicket that comes with pursuing federal aid eligibility, however. As Rachel Fishman, a senior policy analyst for the education policy program at New America, noted in a blog post, existing federal regulations "clearly state that federal financial aid cannot be used to pay for evaluating prior student work." ***New graf here - PF

Accreditors and online learning experts were not immediately able to identify a case to serve as a precedent for the Global Freshman Academy. The examples they used as comparisons -- prior learning assessment and credit recommendations, for example -- suggested ASU won’t face any accreditation issues.

George Siemens, a researcher at the University of Texas at Arlington, presented a deconstructionist view. “This is what has in the past been called ‘distance education’ or ‘online learning,’” Siemens said in an email. “Nothing new here, folks, move along.”

Belle S. Wheelan, president of the Southern Association of Colleges and Schools Commission on Colleges, said gaining approval for the Global Freshman Academy may be as simple as sending the accreditor a letter.

“If they’re not offering any online at all currently, and this is their first foray, then it requires a full-blown prospectus and approval,” Wheelan said. “If they’re already offering online courses and this is just a bigger version, then [it requires] probably just a letter of approval.”

Wheelan stressed she was speaking from the perspective of her accrediting agency, but added that she expected the HLC to give a similar answer.

Paul L. Gaston, a Trustees Professor at Kent State University and author of Higher Education Accreditation: How It’s Changing and Why It Must, nevertheless called the Global Freshman Academy a “retrograde action” for an institution he praised for its innovation.

“It’s a kind of compromise with the values that they have demonstrated in terms of clear learning outcomes and creating exciting environments for learning,” Gaston said. “I do think it represents a shift in the character of the kind of commitment that ASU has been known for.”

Paul Fain contributed to this article.

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