Webinar on New Federal Regulations April 18, 2011

Webinar on New Federal RegulationsApril 18, 2011 Ralph Wolff, President Senior College Commission, WASC Please join the audio portion of this webinar at: 800-926-7748

Announcements Copies of background materials may be downloaded at: http://www.wascsenior.org/node/321 For assistance with Voice and Web connections please contact: ReadyTalk Help Desk: 800.843.9166 International Help: 303.209.1600

Agenda • Review of Credit Hour Regulation • Federal Definition • Institutional Responsibilities • WASC Responsibilities • Review of State Authorization Regulations • State approval requirements • Complaint provisions • Distance education state approvals • Questions Webinar on New Federal Regulations 4-11 3

Credit Hour – How We Got Here • GAO study and IG investigation • Negotiated rulemaking and final regulation • Efforts to have federal definition withdrawn or entire regulation delayed • Regulation goes into effect July 1, 2011 Webinar on New Federal Regulations 4-11 4

Federal Definition (600.2) • Section 34 CFR 600.2 “An amount of work represented in intended learning outcomes and verified by evidence of student achievement that is an institutionally established equivalency that reasonably approximates not less than: 1. One hour of classroom or direct faculty instruction and a minimum of two hours of out-of-class student work each week for approximately fifteen weeks for one semester… or the equivalent amount of work over a different period of time; or Webinar on New Federal Regulations 4-11 5

Section 600.2 (cont.) 2. At least an equivalent amount of work as required in paragraph (1) of this definition for other academic activities as established by the institution, including laboratory work, internships, practica, studio work, and other academic work leading to the award of credit hours.” Webinar on New Federal Regulations 4-11 6

Key Elements • Institutionally established • An amount of work • Represented in intended learning outcomes • Verified by evidence of student achievement • Equivalency that reasonably approximates • 1:2 ratio in to out-of-class • (50 minute hour acceptable) Webinar on New Federal Regulations 4-11 7

Institutional Responsibilities • Adopt and apply policy on credit hour consistent with federal definition • Implement process for assuring “reliability and accuracy” of assignment of credit hours across all credit bearing activities • Incorporate credit hour review into comprehensive self-study requirements Webinar on New Federal Regulations 4-11 8

WASC Responsibilities • Adopt policy and procedure for review of institutional responsibilities • Demonstrate that a review of credit hours is reflected in institutional self-studies and comprehensive team reports • Determine that credit hour assignments “conform to commonly accepted practice in higher education” • May use sampling of course credit hour assignments • Require corrections of deficiencies • Promptly notifies the Secretary of Education if systemic noncompliance is found, or significant noncompliance with one or more programs Webinar on New Federal Regulations 4-11 9

Implementation by Institutions • Assure that credit hour policy is current, applies to all credit bearing activities, and is consistent with 600.2 • Demonstrate that internal processes exist to assure reliability and accuracy of credit assignments, such as: • New course/program approval processes • Program review processes • Ongoing syllabi review processes • Communications to deans, department chairs, program directors and faculty about credit hour criteria Webinar on New Federal Regulations 4-11 10

Implementation by WASC • Will circulate draft policy in mid-May • Will require: • That the institution has a credit hour policy consistent with 600.2 • That the institution assures the accuracy and reliability of credit hour assignments through identified processes for all credit bearing activities • Will include processes for including credit hour evaluations in all comprehensive reviews, including a protocol for sampling • Will require progress reports or special visits to follow up on any deficiencies, and notification to the Secretary, if needed • Will consider credit hour assignments in substantive change reviews Webinar on New Federal Regulations 4-11 11

Sampling Process • DCL: “a varied sample of the institution’s degree and non-degree programs in terms of academic discipline, level, delivery modes, and types of academic activities.” • WASC review and sampling process is likely to include: • Review of institutional polices and credit hour oversight processes (conducted off-site, if appropriate) • Sampling of a small number of course syllabi, if possible, a sample size of 20-30 courses to determine if further review is needed • Special attention given to credit assignments in accelerated and online courses • Results of policy review and sampling included in team reports Webinar on New Federal Regulations 4-11 12

State Authorization – Key Provisions • State approval to operate and award degrees – for private institutions only • State must be able to “receive and act on” complaints – for public and private institutions • All online programs must be able to demonstrate they are operating in accord with state licensing requirements Webinar on New Federal Regulations 4-11 13

Approval to Operate • Section 600.9(a)(1)(i)(A) requires institutions to be authorized by name through statue, charter, constitution, or action by an appropriate State agency or State entity • DCL - Question 3: approval will be accepted if the articles of incorporation are for the establishment of a postsecondary institution by name and filed with the Secretary of State • In California, the BPPE will accept such a filing and WASC accreditation • In Hawaii, we will work to establish a similar process Webinar on New Federal Regulations 4-11 14

Handling of Complaints • State must have a process to receive and act on complaints • For public institutions, state entity can be a governing board if there is sufficient independence from campus • For private institutions, the State “upon considering a complaint, may refer it to other appropriate entities, such as an institution’s accrediting agency, for final resolution.” • WASC is still obligated to process complaints under Federal law in accord with established procedures • In California, BPPE will accept the WASC exemption and refer complaints to WASC for private institutions • In Hawaii and Guam, a process will need to be established Webinar on New Federal Regulations 4-11

Distance Education • Institutions offering online education are required to have approval in all states where state law requires approval and to be able to document that approval is not needed in other states • DCL Question 16 – for 2011-12 good faith efforts to comply will be accepted • A useful resource of state requirements: http://wcet.wiche.edu/wcet/docs/state-approval/FinalStateApprovalRegulationsforDistanceEducationAStarterListwithAddendum.pdf Webinar on New Federal Regulations 4-11

Additional Actions • Efforts are still underway to delay implementation or enforcement of the distance education approval requirement • Continue to let your Congressional delegation know of the impact of both regulations • Provide comments on the draft WASC Policy on Credit Hour Assignment when it is circulated • Share information on how you are addressing both new regulations – a section will be added to the WASC website for interaction on each area Webinar on New Federal Regulations 4-11

Webinar on New Federal Regulations April 18, 2011