Last month, the US Department of Education issued a Notice of Proposed Rulemaking (NPRM) regarding proposed changes to the federal financial aid eligibility of certain distance education courses. For schools that are hoping to go big on distance education, the rules – if adopted – may throw a lot of procedural cold water on courses.
At issue is the ability of institutions to issue federal financial aid for clock-hour asynchronous distance education courses. Clock-hour programs are those based on the actual number of hours per week that a student spends in class, lab or completing the course material. Many schools use a credit-hour designation instead, and the financial aid eligibility question does not apply to credit-hour courses.
However, additional regulations may require schools to take attendance for all distance learning programs, and to withdraw students who have not substantively participated in a course in a consecutive two-week period. Further, the Department of Education may require the return of federal Title IV dollars upon the student’s withdrawal (voluntary or automated) from distance education classes.
The purpose of taking attendance in a distance education course isn’t so much to determine which students are or aren’t present on a given day, but rather to determine whether they are still substantively engaged in the class. Often, distance education courses require discussion board posts, which count as evidence of substantive participation. Under the proposed rules, a student who signs into a school’s learning management system but does not otherwise “participate” would not be determined to participate substantively. So, if a student signs in to listen to a lecture, but does nothing else while signed in, that will not qualify as substantive participation.
Department of Ed may require additional reporting and refunds
The upshot here is not whether clock-hour programs are in jeopardy (they are), or what counts as “participation” in terms of federal financial aid. Rather, the most notable thing about the proposed rulemaking is that the Department of Education has turned its proverbial Eye of Sauron toward distance education classes, period.
There is a growing concern that distance education coursework does not offer the same rigor as in-person classes do. That suspected lack of substance in distance education classwork has implications for both federal financial aid eligibility and accreditation.
Schools that wish to substantially increase their distance education programs would be well advised to understand that such a strategy will also increase their exposure to scrutiny by both the US Department of Education and their friendly, neighborhood accreditor. In addition, such a strategy could end up triggering substantial tracking and reporting requirements, as both entities attempt to ensure that the quality of online education remains comparable to that of in-person education.
Photo Credit: Kevin Gill, via Flickr
