1. TRACS Annual Meeting October 28-30, 2015

2. Critical Issues in the Developmement, Implementation, and Management of Distance Education Programs

3. Critical Issues TRACS Approval Legal Authority Distance Education vs Correspondence Education Platform Cost and Affordability Management Model of Distance Ed Comparability of Online and On-Campus Classes Library Resources Faculty Student Services Logistics Commitment

4. First Step in the Development of Distance Education Programs Conduct a Needs Analysis and Feasibility Study Establish a need Once a need is established, entertain the feasibility of implementing the program A substantive change request must be submitted to TRACS You need the information from the needs analysis and feasibility study for the substantive change

5. Issue #1: TRACS Institutional Change Form Distance Education is a C-3 institutional change which involves the addition of courses or programs that represent a significant departure for current offerings. Distance Education is a C-3 change. You must address the following: – A1 – A4 – B1 – B3 – J4 A staff or focus visit may be required.

6. Issues to be addressed in the TRACS Institutional Change Form Detailed Description Number of Students Target Audience Projected Life of Program Instructional Delivery Methods Relationship of Change to mission and goals Legal Authority ( a critical issue within itself) Relationship to on- campus programs

7. Major areas to be addressed – each major area has several subpoints to be addressed Assessment of Need – Needs Analysis Educational Programs - Course Syllabi Course offerings, admissions and graduation requirements Grading, transcripts, transfer policies Administrative oversight Faculty – roster, course load, sufficient faculty, access to faculty Library Learning Resources Physical Resources Financial Support – financial impact Assessment

8. Issue #2: Second Major Step – Provide Evidence of Legal Authority Standard 5.2 Institution has legal authorization to operate from the government of all states or territories where the institution enrolls or intends to enroll distance education students and has filed copies of the authorizations with TRACS, except if (1) the institution is exempt from the requirement to register in a state, the institution shall provide documentation of that exemption to TRACS or (2) any state in which it enrolls or intends to enroll distance education students does not require any institution to obtain such authorization, the institution shall provide this information to TRACS.

9. Requirement for State Authorization Accrediting Agency State Law US Department of Education is in the process of re-instituting the requirement for state authorization in the states in which you offer distance education as a requirement for federal financial aid.

10. The Requirement The Institution must have approval from every state in which distance education courses are offered. The regulations and requirements vary from state to state. Some states require approval and the submission of an application – an extensive process. Some states do not require approval. Some states only require notification.

11. The Requirement (continued) The terminology varies from state to state. Usually, the issues are physical presence, advertising, and internships. Some of terms that you might encounter: authorization, registration, licensure, exempt, religiously exempt. Some states have an annual or bi-annual renewal.

12. The Requirement (continued) Note the handout from Luther Rice summarizing the status of the requirements from each state. The State Higher Education Executive Officers (SHEEO) is the best source for whom you contact in each state. In some states, you have to contact more than one person or agency. http://sheeo.org/sheeo_surveys

13. The Requirement (continued) Requirements also depend on the nature of your institution. Do you primarily exist for ministry training? Usually requirements are different for liberal arts institutions. Many who require some level of approval require a fee.

14. Issue #3: Distance Education vs. Correspondence Education The Higher Education Opportunities Act (2010) defines distance education as education that uses one or more technologies to deliver instruction to students who are separated from the instructor and to support regular and substantive interaction between the students and the instructor, synchronously and asynchronously.

15. Technologies 1. Internet 2. One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines fiber optics, satellite, or wireless communication devices 3. audio conferencing 4. or video cassettes, DVDs, and CD-ROMS One or more

16. Correspondence Education 1. Education provided through one or more courses 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. 2. Interaction between the instructor and the student is limited, is not regular and substantive, and is primarily initiated by the student.

17. Correspondence Education continued 3. Correspondence courses are typically self- paced. 4. Correspondence education is not distance education.

18. The focal issue Only distance education can qualify for federal financial aid; correspondence education cannot. In addition to compliance audits by USDE, audits are being done by the USDE of courses in which federal financial aid has been awarded to determine if the courses meet the definition and parameters of distance education. If it is determined that the courses are not distance education and financial aid has been awarded, the Institution may have to repay the money awarded. The penalties are stiff.

19. The implications Some of our Institutions have been audited. There are institutions outside of TRACS that have been audited.

20. Federal Regulations require “regular and substantive interaction between the students and the instructor.”

21. Definitions Regular is interpreted as weekly interactions in a regular term, eight-week mini-term, or any shortened version of a term. Substantive is interpreted as feedback that addresses both the accuracy of a student’s work, and offers further communication for assistance. Merely typing “good job” is not considered substantive feedback. There are feedback mechanisms in the MLS, like Blackboard, which can assist in the process.

22. Definitions continued Interactions can take place through many media. Interactions include e-mail exchanges, feedback on assignments, posting on discussion boards, Q&A sessions, blogs, synchronous teleconference exchange, announcements, phone calls, etc. Professors are encouraged to use a variety of assignments in which they provide feedback.

23. Definitions continued Students is interpreted to include both the individual and the class as a whole. In other words, each student must receive personal/individual interaction with their instructor each week at a minimum. The class as a whole may receive interactions with their instructor each week.

24. Definitions continued Instructors is interpreted to include both the professor of record and the teaching assistant(s).

25. Some Examples 1. Weekly announcements to the class as a whole, by the professor, that addresses his/her reflections from the prior week. 2. Weekly feedback on assignments, to each student, by the teaching assistant, that addresses the student’s performance, and invites further interaction. 3. Weekly phone call to “at risk” students, by the professor, that addresses the individual needs of the student.

26. Notes All interactions must be reflected in the syllabus (a syllabus statement). All interaction must be documented and archived. All assignments that include interaction must be graded assignments. Instructors must respond to contacts and requests within 24 hours.

27. Notes continued The instructor must initiate the interaction. When you use a learning management system, you must use the tools that are provided and require student involvement. The requirements must be included in the syllabus, and the institution must demonstrate faculty driven interaction.

28. Guide to Regular and Substantive Interaction in Distance Education Let’s review this policy from Luther Rice College and Seminary

29. Sample Syllabus Statement “Instructor-student interaction is a key component to learning, and this is no less true for distance education and online education. Therefore, as a student at Luther Rice, you can expect you instructors (professors and teaching assistants) to be responsive to your questions or concerns. On weekdays, you can expect a response within twenty- four hours, on the weekends allow forty-eight hours. Instructors also will initiate contact with you, so it is essential that you monitor your Luther Rice email daily, review comments and feedback on assignments, and remain actively engaged no less than several times a week in your course(s). Your grade in the course depends on your attentiveness to the instructors and directions given to you by your instructors. You are responsible for knowing the syllabus, deadlines on assignments, school policies, and all communication from the instructors to you personally and to the class as a whole.”

30. The summary statement and importance of the issue If it is deemed that an Institution has correspondence classes and 50% or more of the students have taken those classes and received federal financial aid, the Institution must repay the federal financial aid.

31. Issue #4: Platform Bb Blackboard – proprietary and costs Moodle – free and open source Populi (this management system includes a learning management system) Many Platforms -Functionality -Cost

32. Issue #5: Cost and Affordability Distance education is not necessarily a “cash cow.” It does not run itself. It must be managed. It must be included in your budget process.

33. Issue #6: Management Distance education must be part of the academic sphere of an Institution. It should not be separate from the faculty. It should be part of the curriculum. It should be part of the administrative structure of the Institution. It must be managed. There must be accountability. There should be a Distance Education liaison.

34. Issue #7: Model of Distance Education How will the courses be delivered? What methodology will be used? What is the exact format of classes? What are the length of the classes – 15 weeks full semester, 8 weeks? How many online courses can an on-campus student take, if any? Will there be videos, lectures? Will students only take courses or be able to earn a degree? How will practicums and internships be handled? Will a course be taught totally using distance education, partially using distance education, or flipped?

35. Issue #8: Comparability of Online and On-Campus Classes Same student learning outcomes Different methodology Same syllabi Grading and grades

36. Issue #9: Library Resources There must be library resources to support the curriculum – databases, full-text, ebooks, journals. These resources require financial commitments. In most cases, these resources require subscriptions. The Institution must provide resources.

37. Issue #10: Faculty Will you use on-campus and full-time faculty? How many adjunct faculty will you have to hire and use? What are the budget considerations? Will the faculty be equally qualified? How do you guarantee faculty congruence with mission? How will you do professional development? How are courses developed?

38. Issue #11: Student Services What Student Services will you provide? Will you offer chapel to your distance education students? How will you communicate with students? How will you develop and cultivate a sense of community? How will you handle complaints and issues? How will you handle academic advising?

39. Issue #12: Logistics Application Admissions Registration for classes Graduation Transcripts 24/7 service Security Faculty and Staff Office Hours IT Support

40. Issue #13: Commitment

41. Final Comments TRACS Standards 12.1 – 12.19 deal with distance education. Consult Best Practices in Distance Education. The Development, Implementation, and Management of Distance Education requires planning and resources!