Substantive Change, SACS and Electronically-delivered Programs FDLC Panel Presentation May 15, 2009

Comprehensive Standard 3.4 Educational Programs: All Educational Programs (includes all on-campus, off- campus, and distance learning programs and course work) (See Commission policy “Distance Education.”) From: The Principles of Accreditation, Southern Association of Colleges and Schools, Commission on Colleges, 2008 Edition

SACS Distance Education Policy Statement Curriculum & Instruction Library & Learning Resources Student Services Facilities & Finances

Curriculum & Instruction Timely and appropriate interaction Faculty responsibility – oversight of distance education Appropriate technology Currency of materials, programs, and courses Clear policies for ownership, compensations, copyright and use of revenue Support services for distance education Training for distance education faculty Admissions policies and capability of students to succeed in distance education programs Comparability of distance education to campus-based programs Ensure integrity of student work, credibility of degrees and credits

Library & Learning Resources Access to resources Instruction in use of resources Course requirements Access to facilities

Student Services Access to services Procedure for resolving complaints Accuracy and adequacy of information Technology: ability, equipment needs, assistance

Facilities & Finances Required equipment and expertise Long-range planning, budgeting and policy development reflect needs of distance education programs

Some Red Flags (From “Evidence of Quality in Distance Education Programs Drawn from Interviews with the Accreditation Community,” U.S. Dept. of Educ., 2006) Approval procedures differ from traditional courses (e.g. not reviewed by faculty curriculum committee). Students express dissatisfaction with quality “Cookie-cutter” approach Discussion board shows little activity Rapid turnover of adjunct faculty teaching online Wide variation of student evaluations between fulltime faculty and adjuncts teaching online Faculty have primary responsibility for tech support Course materials have not been updated

Red Flags con’d Interviews indicate growth in DL enrollment exceeds capacity to provide adequate academic and student support services Lack of success in follow-up courses after taking a pre-requisite online Trends over time indicate declining completion and retention Fully online programs that require students to come onsite for student services Same complaints received semester to semester

Evaluation & Assessment Excerpt from “Evidence…” Evidence of educational effectiveness at institutions offering distance education programs differs little from the evidence reviewers look for at institutions offering no distance education. Essentially, reviewers want to know how the institution measures student learning, how it assesses the experiences that lead to those outcomes, and what changes it makes based on the assessments.

Substantive Change Defined A significant modification or expansion of the nature and scope of an accredited institution. Federal regulations stipulate that, at a minimum, substantive change includes: Any change in the established mission or objectives of the institution Any change in legal status, form of control, or ownership of the institution The addition of courses or programs that represent a significant departure, either in content or method of delivery, from those that were offered when the institution was last evaluated

Substantive Change Defined Some changes, such as offering courses on- line that amount to less than 25% of the coursework needed to complete a degree, certificate or diploma, do not need to be reported to the Commission. Others, for example offering from 25% to 49% of the coursework required for a program on-line, simply require that the Commission be notified in advance of the implementation of the change.

Substantive Change Defined Larger scale changes, such as adding significantly different programs to the academic curriculum or offering a majority of the coursework needed to complete a degree, certificate or diploma on-line, require written notification at least 6 months in advance and approval of a prospectus, which must be submitted at least 3 months prior to the anticipated implementation date.

Why Does SACS Care about Substantive Changes? It is important for the Commission to understand how your institution is evolving and growing by: reviewing proposed changes in terms of the institutional mission considering the impact of change on existing programs determining whether the institution has sufficient resources to implement the change evaluating the soundness of the proposed change

Substantive Change Policy is Not New The policy on substantive change has been in place a long time. What is new is the inclusion of a separate item in the Comprehensive Standards ( ) referring specifically to reporting substantive changes. If a college has not reported a substantive change, it is out of compliance with the Comprehensive Standards.

SACS Substantive Change Policy January 2007 It is the responsibility of an institution to follow the substantive change procedures of the Commission and inform the Commission of such changes in accord with those procedures.

SACS Substantive Change Policy Initiating distance learning (where the instructor and student are geographically separated) — Offering 50 percent or more of program Procedure One for the Review of Substantive Changes Substantive change requires notification, submission of an application or a prospectus*, and approval by the Commission on Colleges prior to implementation by the institution  Requires at least 6 month’s Notification prior to implementation, and Approval  Subsequent programs do not need reporting unless they are significant departures from initially approved program(s).

Contents of Prospectus Cover sheet Abstract (limit to one page or less) Background information Nature and purpose of change Assessment of need & program planning/approval Description of the change Outcomes & learning objectives of the program Faculty Complete roster Describe processes in place to ensure that students have structured access to faculty. Library & Learning Resources Physical Resources Financial Support Business Plan & Contingency Plan Evaluation & Assessment Institutional Effectiveness & Quality Assurance Processes describe the methodology for determining that levels of knowledge and competencies comparable to those required in traditional formats have been achieved. Appendices

SACS Substantive Change Policy Offering 25 to 49 percent or more of a program Procedure 2 for the review of substantive changes Notification prior to implementation required (thereafter reporting 50 percent or more of a degree program or an entire degree program) Adding significantly different programs (approved for the institution) from previously reported programs offered through distance learning Initiating significant changes in existing technology-based delivery systems in distance learning/off-campus programs Offering 24 % or less of a program No requirements

SACS Substantive Change Policy If an institution is unclear as to whether a change is substantive in nature, it should contact Commission staff for consultation.

SACS Substantive Change Policy Upon receipt and review of the substantive change notification, Commission staff will recommend one of the following options to the President of the Commission: acknowledge receipt of the notification and indicate that the change will be included in the scope of the institution’s accreditation or acknowledge receipt of the notification and request additional information**.

SACS Substantive Change Policy Upon receipt of additional information, if requested, Commission staff may: Acknowledge receipt of the additional information and include the change in the scope of the institution’s accreditation; Refer the substantive change to the Commission for review; Authorize a substantive change visit; Take other action as may be appropriate.

Broward College Substantive Change for Electronically- Delivered Programs Submitted September 10, 2007 Requested approval to offer a limited number of associate degrees and certificates through distance education beginning in January, Requested approval to offer other fully online programs as they are developed for which “there is a match with the needs of future students.”

Broward College Substantive Change for Electronically- Delivered Programs Prospectus Linked College’s Education Master Plan to its Strategic E-learning Plan. Included 5 fully online degree programs and 4 online certificate programs. Made case for equivalent online academic and student support services Cyber advisors Online tutoring & writing lab

Broward College Substantive Change for Electronically- Delivered Programs Prospectus Described faculty professional development, technology mentoring and Faculty E-learning Associate support services. Included existing faculty credential information from college’s database, copied into the SACS faculty roster form. Described student access to library databases, reference librarians (Ask a Librarian), and bibliographic instruction modules that are integrated into e-learning courses.

Broward College Substantive Change for Electronically- Delivered Programs Prospectus Described e-learning infrastructure and help desk services (Sungard Higher Education). Provided a first year operating budget that reflected income and specific e-learning expenses ($1.2 million). Described BC’s evolving institutional effectiveness model.

Broward College Substantive Change for Electronically- Delivered Programs Prospectus Described quality control mechanisms: Online course development process Course review & approval process Collection of data on student success using business intelligence software

Broward College Substantive Change for Electronically- Delivered Programs Submitted letter and prospectus September 11, 2007 Received SACS response on November 6, 2007 “How does the institution determine comparability of learning outcomes between those students enrolled in an online course and the students enrolled in the same course taught in the traditional classroom setting?”

Broward College Substantive Change for Electronically- Delivered Programs SACS response (continued) “Please document and justify the qualifications of the following (16/125) faculty.”

Broward College Substantive Change for Electronically- Delivered Programs Broward submitted response April 30, 2008: For comparability of learning outcomes— Specific learning outcomes are derived from course outlines E-learning Course Development Agreement includes, “I agree to develop the course so that it meets the existing student learning outcomes as stated in the course outline.” E-learning professional development outcomes require that faculty link specific learning outcomes with learning activities, and learning assessment. BC’s IE and LO Plan, to be completed by January, 2009

Broward College Substantive Change for Electronically- Delivered Programs For faculty credentials: Removed problematic faculty that were not teaching online courses in the specified degree and certificate programs. Substantially expanded credential information for the remaining 8 faculty with assistance of associate deans.

Broward College Substantive Change for Electronically- Delivered Programs SACS response, June 18, 2008 “The information supplied on comparability of learning outcomes and faculty credentials satisfactorily addressed our concerns. We approve your proposal, shall include it within the scope of accreditation previously granted, and wish you and your colleagues much success with it.”