Caution on Competency

Education Department's Office of Inspector General criticizes a regional accreditor over its review of competency-based education programs, citing faculty role.

October 5, 2015

The U.S. Department of Education’s Office of Inspector General has pumped the brakes on competency-based education, partially due to concerns about the level of interaction between instructors and students in some of those programs.

Last week the inspector general issued a critical audit on the review process that the Higher Learning Commission, the largest regional accreditor, undertook while considering colleges’ proposals for new competency-based credentials.

The audit builds on similar concerns the inspector general raised last year. It could have a chilling effect on competency-based education's growth, said experts and advocates for such programs. More than 600 institutions are in the design phase for a new competency-based credential or already offer them.

“This is a totally arcane issue that could have a huge impact on how we offer different kinds of education,” said Amy Laitinen, deputy director for higher education at New America and a former official at the White House and the Education Department. “Folks are going to be really nervous.”

The inspector general operates independently at the department, reviewing its programs with audits and investigations. And while the department has been enthusiastic about competency-based education, that isn’t always the case for the inspector general.

The office last year issued an audit that criticized the department’s approval of direct-assessment degrees, which are competency-based credentials that do not rely on the credit-hour standard. The audit questioned the sufficiency of the faculty role in those programs, and raised concerns about low-quality providers entering the space.

Around the same time, the inspector general began reviewing the Higher Learning Commission’s review process for both direct assessment and other types of competency-based programs. As a result, the HLC temporarily froze new approvals of competency-based degrees last year.

The department later issued more guidance on competency-based education, including a voluminous document that went live last month. Likewise, a group representing regional accreditors recently attempted to clarify how competency-based programs should be classified and reviewed.

Experts said those documents helped colleges and accreditors feel more comfortable as they moved forward with new competency-based credentials. But the latest audit from the inspector general strikes a cautionary note.

“We concluded that the Higher Learning Commission did not establish a system of internal control that provided reasonable assurance that schools’ classifications of delivery methods and measurements of student learning for competency-based education programs, including direct assessment programs, were sufficient and appropriate to help the department ensure that it properly classified the schools’ programs for Title IV purposes,” the report said.

As with its audit last year, the inspector general raised concerns about federal aid program requirements for “regular and substantive” interaction between faculty members and students in academic programs.

In some cases, the audit said, competency-based programs might need to be labeled as correspondence courses under federal rules for faculty interaction. And that classification could affect aid eligibility.

“We recommend that the assistant secretary require the Higher Learning Commission to reevaluate competency-based education programs previously proposed by schools to determine whether interaction between faculty and students will be regular and substantive,” the report said, “and, if not, determine whether the programs should have been classified as correspondence programs.”

A spokesman for the Higher Learning Commission said the accreditor respects the work of the inspector general, and is working to respond to the audit.

“HLC seeks to balance the recommendations as we simultaneously strive to encourage innovation at our member institutions,” he said.

The audit shows the need for clarity and more communication on the definitions, requirements and processes for competency-based education, said Laurie Dodge, vice chancellor of institutional assessment and planning and vice provost at Brandman University.

"If institutions and accreditors have a clear understanding of the components of competency-based education, especially credit-hour equivalencies of direct assessment and regular and substantive interaction between faculty and students, we can and must build these innovative programs to meet student needs," said Dodge, who also is co-chair of the Competency-Based Education Network (C-BEN), a Lumina Foundation-funded group that is comprised of institutions that either have competency-based degrees in place or are creating them.

Laitinen said the audit’s take on correspondence courses is based on policies that date to the 1980s, long before recent developments in online course delivery that are being used in many competency-based degree programs. She called on the U.S. Congress to redefine what “regular and substantive” should look like -- in ways that are both more relevant and that protect students.

Mike Offerman agreed, albeit in stronger terms. Offerman is a president emeritus of Capella University who has long worked on competency-based programs. He said the Office of Inspector General has taken an “activist” approach with its audits on competency-based education.

“The findings are regressive,” he said via email, “ignoring the hard work being done by a number of higher education institutions dedicated to responsible innovation.”

Offerman said the risk of throwing open the doors to programs of inadequate quality is a real one. But he said the inspector general’s approach to that threat is the wrong one.

“What we need is well-considered action with adequate safeguards and appropriate expectations for demonstrable outcomes to optimize the potential benefits of competency-based education while effectively stewarding Title IV resources,” he said. “I know that the institutions that continue to work diligently to assure development of high-quality competency-based education programs stand ready to help define just how to get this right.”


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