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In a recent letter to the Higher Learning Commission, the largest of the regional accreditors, the Office of the Inspector General offered a scathing review of the commission’s approvals for direct-assessment competency-based education programs. The review highlighted the fundamental challenges facing a movement that has been washing like a wave over higher education. The OIG’s more rigid reading of the rules for faculty interaction with students may have a chilling effect on accreditors, who could become more concerned about running afoul of the OIG than of heeding calls to be supportive of much-needed innovation in higher education.
In just two years, we have gone from a handful of CBE programs and almost none offering direct assessment -- the unwieldy name for CBE programs not tied to the credit hour -- to more than 600 institutions working on such offerings. Those institutions include community colleges, independent colleges and universities, and public institutions like the University of Michigan and the University of Texas. In contrast to the rapid expansion of for-profit online education a decade ago, the primary providers today are nonprofit institutions. While most programs are still being designed within traditional credit-hour frameworks and thus Title IV rules of financial aid disbursement, an increasing number seek to be untethered to the credit hour and its trumping of time over actual learning. They have the support of leaders in the Education Department, the White House and both parties of Congress.
Enter the OIG, which operates independently within the Education Department, auditing and investigating department programs. The recent letter to the Higher Learning Commission reasserts the use of the “regular and substantive interaction between faculty and students” rule to distinguish between conventional Title IV-eligible programs and correspondence programs, which have greater restrictions on aid eligibility and ruinous stigma attached to them. The OIG, acutely aware of the abuses in correspondence programs in the 2000s, takes a very conservative interpretation of the rule and posits a traditional faculty instructional role.
However, many of the most innovative CBE programs unbundle that role, using faculty members in various ways, such as subject matter experts, reviewers and for learning support, while relying on “coaches” for some of the advising and mentoring roles often associated with faculty. Such programs are also introducing breakthrough technologies that can offer personalized learning and robust support not possible just 10 years ago.
The Education Department’s own guidance to institutions tacitly acknowledged such an unbundling process in its December 2014 dear colleague letter when it talked about interactions between students and "institutional staff," and it offered more explicit guidance this September in its Competency-Based Education Experiment Reference Guide. That detailed and much-awaited guidance reaffirms the need for students to have “access to qualified faculty,” but it allows for the unbundling of faculty roles, for “regular and substantive” interaction to be “broadly interpreted,” and for “periodic” interaction to be “event driven.” It shares the OIG’s basic concern when it asserts that “it is incumbent on the institution to demonstrate that students are not left to educate themselves, a chief characteristic of correspondence programs.” But it also understands that there are now many exciting alternatives to “self-learning” that do not look like traditional classrooms.
A lot of the innovation underway in CBE rests on adaptive learning technologies, powerful analytics and customer relationship management tools, learning science, and improved practices in everything from advising to learning design. But those advances -- all emerging after the correspondence program abuses of 20 years ago -- are unacknowledged in the OIG’s report. And the report’s authors continue to use time as a proxy for learning, as when they use phrases like, “even though the applications described the proposed programs as self-paced ….” Pacing is largely irrelevant in a direct-assessment world where outcomes, not seat time, matter.
The report rightly points out a need for clarity of approval processes and better communications. Institutions have long been frustrated by the opaque nature of both the Education Department’s and at least some of the accreditors’ approval processes, including the Higher Learning Commission’s. Yet, ironically, just as the accreditors and the department have improved their guidance -- witness the Council of Regional Accrediting Commissions' guidance in June and the department’s expanded CBE guidance in September -- the OIG report will very likely make things worse again as both parties scramble to respond and alter their processes in whatever ways they feel necessary.
New Regulatory Frameworks
Congress can fix this mess (come on now, hold back that snickering). It can create a demonstration project that allows non-credit-hour CBE -- let’s please drop “direct assessment,” as all CBE programs directly assess student mastery of competencies -- the kind of latitude for providing the functions that faculty have traditionally provided, while not reifying their roles. It can use the occasion to also provide for subscription models of disbursing Title IV, rethinking time-based measures like Satisfactory Academic Progress, tying aid disbursement to mastery of competencies and finally, getting Title IV rules to align with the legislative intent of an alternative to the credit hour.
It can then use that demonstration project and what we learn from it to inform the reauthorization of the Higher Education Act. Given the bipartisan support for CBE, the demonstration project can be easily created, and it would be a useful mechanism for informing the more complicated process of reauthorization. Republican Congressman John Kline of Minnesota, chair of the House Education and Workforce Committee, can immediately address the need by reintroducing last year’s widely supported CBE bill. Former Senator Tom Harkin, a Democrat from Iowa and then chair of the Senate Health, Education, Labor and Pensions Committee, would not take up the bill, a missed opportunity. His successor in the Senate, Republican Senator Lamar Alexander of Tennessee, should consider a demonstration project as a useful step towards reauthorization, a source of learning to inform better policy making, and act to support the innovation he has rightly called for in HELP Committee hearings.
In the end, the OIG is simply enforcing the law and rules that Congress and the Department of Education have created. While its lawyers, auditors and investigators are by nature and training biased toward a more conservative, even rigid, reading of the rules, it is not their job to make the rules. They will enforce what Congress creates.
So the onus is on policy makers to create new regulatory frameworks with enough latitude to better provide for innovation and the learning still underway, enough quality assurance to discourage shoddily designed programs, and enough regulatory oversight to prevent the abuses that still inform the OIG’s concerns with CBE programs.
