- Lewis Carrol, Alice in Wonderland
This article from the Chronicle of Higher Education popped up on my Facebook feed recently.
Western Governors U. Might Have to Repay $700 Million in Student Aid
$700 MILLION! Why?
I did a little searching, and found this article from Inside Higher Education that had a little more information.
Federal Audit Challenges Faculty Role at WGU
In essence, what the report found was that WGU's online course offerings lacked "regular and substantive interaction between students and their instructors" rule for online courses. Instead, their courses were considered "correspondence courses." If an institution offers more than 50% of its courses as correspondence courses, it is ineligible for Title IV financial aid funds.
While WGU was under scrutiny for its competency-based education model, the "regular and substantive interaction" rule was put in place when distance education courses became eligible for federal financial aid. Financial aid was limited for correspondence or "telecourses" because of the rampant fraud that became widespread when GIs returned from war with GI Bill education money available, but little time to take traditional college courses. In the early 90's, Congress limited the amount of aid available to students taking correspondence courses; to do so, they had to define what a correspondence course was:
Correspondence course: (1) A course provided by an institution under which the institution provides instructional materials, by mail or electronic transmission, including examinations on the materials, to students who are separated from the instructor. Interaction between the instructor and student is limited, is not regular and substantive, and is primarily initiated by the student. Correspondence courses are typically self-paced.
Fairly recently, distance education was defined as:
Distance education means education that uses one or more of the technologies listed in paragraphs through (4) of this definition to deliver instruction to students who are separated from the instructor and to support regular and substantive interaction between the students and the instructor, either synchronously or asynchronously. The technologies may include -The primary difference between these two definitions is the phrase, "regular and substantive interaction between the students and the instructor." While the definition of distance education requires the use of technology for content delivery and communication, there is nothing in the definition or correspondence courses that precludes its use.
(1) The Internet;
(2) One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
(3) Audio conferencing; or
(4) Video cassettes, DVDs, and CD-ROMs, if the cassettes, DVDs, or CD-ROMs are used in a course in conjunction with any of the technologies listed in paragraphs (1) through (3) of this definition.
In terms of financial aid, this isn't a big issue for us (the DOE has many bigger fish to worry about there), but it is in terms of accreditation. Middle States clearly states in its distance education guidelines that "Course design and delivery supports student-student and faculty-student interaction." While they don't say in what format or how frequently that interaction occurs, if students can make it through your online class without any contact from you - or without you ever seeing any work they do - then your course doesn't meet that criterion. It might be a correspondence course...
Definitions
What constitutes "regular and substantive interaction?" A key concept to remember in trying to interpret distance education requirements is the general purpose: to ensure that students enrolled in distance education classes get an educational experience equivalent (not equal) to that which they receive in the traditional classroom. According to a presentation by representatives of the Department of Education, "regular and substantive interaction" should meet the following criteria at a minimum:Regular:
You interact with your students in the classroom on a regular basis, so you need to interact with your online students on a regular basis. Students also need to know when they are expected to interact with you or with each other and that interaction must be required, not optional. That doesn't mean the interaction needs to be face-to-face (equal) or even in real-time. It does need to occur at regularly scheduled intervals; since classroom courses meet a minimum of once a week, you should interact with your online students at least once a week. It should also require some sort of response from the student to make it an interaction, not just an action on your part. These interactions also need to be initiated by the instructor; students asking for help or clarification, for example, do not meet this criteria.Substantive:
To be substantive, it has to be detailed and related to the academic content. A grade is not substantive. Providing individualized feedback to an assignment is substantive. Answering a technical question about the course is not substantive; answering a question to explain specific course content is. An auto-graded quiz is not substantive, even if students receive automatic feedback on each question, because they are not interacting with the instructor, just the technology.Sample Activities
What sorts of activities can you include in your course to meet this? Anything that you initiate, students respond to, and you respond back meets the criteria. Usually these activities will require students to write something that you respond to, rather than just answer multiple choice questions. Here are just a few examples:Discussions
This is the most obvious way to meet this requirement. You can include a weekly discussion topic in which students are required to participate and in which you participate as well. You should require not only an initial posting, but define a minimum number of responses students need to make.You don't need to respond to every posting, but you should monitor the discussion two or three times a week, and respond to at least some of the postings. You might answer questions students have or steep the conversation in a specific direction so students consider alternative viewpoints.
You can make this a graded discussion and use a rubric to streamline the grading process. This is another way to meet that "substantive" portion of the requirement, because it gives you another opportunity to provide individualized feedback to students and to tell them how to improve their performance in the course.
I use discussions to move beyond the textbook into less concrete topics. Sample discussions in my astronomy course include space exploration funding (should it be public or private), sexism and racism in science, what part of the Solar System should we explore next, and will we find signs of life elsewhere in the universe in our life time. These are all topics that don't have a right or wrong answer and give students a chance to look beyond the hard facts of a topic and form and support an opinion.
Blogs
Similar to discussion, blogs can be weekly requirement. However, instead of a "back and forth" exchange like a discussion, blogs are a single posting with comments. Again, like discussions, you need to define for students the required level of a participation, and you need to read an comment on student blogs as well. You can use rubrics to grade blog participation as well.I've used an "In the News Blog" assignment for several years. I give students a specific topic, and they need to find an online news article (with very loose definitions of "news") to blog about. The blog has a specific format, with requirements for format and summarizing, and students must comment on at least two postings from their classmates. As with discussions, you should respond to blog postings a couple of times a week by posting your own comments; you could even post your own blog as an exemplar for student work.
A key part of this assignment is the requirement for students to include a question they still have after reading their article. I can answer the question by commenting on the blog or in the feedback when I grade the blog assignment. This allows me to meet the substantive portion of the interaction requirement.
Written Assignments
Rather than relying solely on auto-graded assignments (which do not meet the substantive portion of the interaction requirement, since they provide only a grade and not specific feedback from you as the instructor), include written assignments as well. These could be essay questions on chapter quiz or separate assignments that require more in depth writing.I include weekly virtual labs or critical thinking assignment in my courses. Students need to answer specific questions, submit their assignment as Word document attachment, and I provide specific feedback when grading.
Collaborate Sessions
Every faculty member who uses Blackboard Learn has access to Blackboard Collaborate, Blackboard's web-based conferencing tool. You can use Collaborate to run a real-time lectures or discussions with students online. The challenge for using it to meet the regular and substantive interaction requirement is requiring students to attend the session. It is difficult to find a time when all online students are available to meet online; most online students take online courses because of time flexibility. However, if participation is NOT required, it doesn't meet the regular and substantive interaction requirement.You can get around this in a couple of ways. You could offer the same session twice, for example, in order to give students more options. If you make this time requirement known to students upfront (through information in WebAdvisor or on the Online Course Request form), students will know that they need to schedule their time appropriate. You can also record the session, and require students to watch the video and complete some written activity to which you respond based on the recording.
While holding online office hours is an excellent use of Collaborate, and one all faculty should employ, they don't meet the "regular and substantive interaction requirement." Just like office hours don't meet the requirements for class time in determining credit hours, online office hours are not considered regular and substantive interaction. Students are not required to attend office hours, so while you may offer regular office hours, student participation is not considered to be regular.
Looking Ahead
These aren't the only activities that can meet the "regular and substantive interaction" requirement. I would love to hear about any examples you might have; please post them in the comments. As long as they:- are initiated by the instructor
- require a student response
- occur at regular, relatively frequent intervals
- relate to academic content
- allow you to provide a response or individualized feedback to the student
they can meet this requirement.
Again, we are not in danger of having to return financial aid money like Western Governors University, but our next Middle States accreditation visit is just around the corner. You should implementing activities in your online courses now to meet the regular and substantive interaction requirement before we are forced to do so in order to be able to continue to offer online course and programs and maintain accreditation. Even one activity a week that meets these criteria will improve our chances of meeting accreditation requirements, and more importantly, improve our online courses.
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