January 20, 2018

Does the U.S. accreditation system discriminate against online learning?

Vedder, R. (2012) The Unholy Alliance Against Online Learning, Bloomberg, October 29

Yes, says Richard Vedder, professor of economics at the University of Ohio. He points to examples such as Minnesota, which briefly banned Coursera courses because they had not been accredited in the state, Ashford University, whose online courses are accredited in one region, but refused accreditation in another, and the Federal government requirement that online programs must be separately approved by every one of the 52 states individually (now under challenge in the courts), which is an onerous, costly and time-consuming requirement.

I certainly don’t claim any expertise in the arcane system (if it can be called that) of accreditation in the USA, but I think there are several separate issues at play here, and they need to be treated somewhat differently:

  • it is difficult to argue that there is a ‘system’ of accrediting institutions or programs in the USA; as Vedder says, it is a patchwork quilt, with varying standards. It is self-regulatory, and each institution picks and chooses whatever agency suits its purpose. There is no direct relationship between accrediting boards and state legislative supervision of institutions. The entire US accrediting system is incredibly confusing and misleading for potential students and should be thoroughly overhauled; but that ain’t going to happen, because of the decentralized nature of higher education in the USA.
  • one reason for the extremely cautious approaches of the federal and state governments in the USA to the accreditation of online courses is the long history of dubious practices by for-profit higher education institutions. Unfortunately, online and distance have become equated in legislators’ minds with for-profit education, which is now reaping what its earlier practitioners sowed: widespread distrust. However, if there had been integrity in the accreditation system, the for-profits would have been prevented from driving a coach and horses through the accreditation process
  • this bizarre system was worked around when education was delivered locally. States could exercise some element of control over what was happening on campuses within the state. This just doesn’t work though for distance or online learning, which can originate anywhere, not just in the USA, but from across the world.

Another barrier: the Carnegie unit of measurement

The Carnegie unit of measurement, based on time in class (e.g. three credit hours a week based on hourly lectures) doesn’t work for online learning. The US Department of Education uses the Carnegie system to determine whether a student is full-time or not, i.e. that the student takes 30 credits a year, in order to get financial aid. However, online learning does not fit the model of 39 hours of lectures over 13 weeks. Modules of learning can be much shorter or much longer, depending on the ability of the students and the needs of the teaching. What is being measured through the Carnegie system of ‘accumulating’ credits is not learning, but time spent studying.

Quite apart from discriminating against all part-time learners, making the Carnegie unit the basis for funding causes all kinds of problems for innovative ways of delivering programs to learners in the 21st century. Most learners are in essence part-time these days (average time to a bachelor’s degree in the USA is between six and seven years). Institutions such as Western Governors University, which provides an accelerated path for those already with defined competencies, has to build its competency-based training into ‘chunks’ that equate to Carnegie units, so that students qualify for financial aid. Innovative online courses have to equate to the amount of time students on campus would spend taking the same course, which is a hazy figure at best. We should be measuring outcomes, what students have learned, not how long they have spent learning it.

What should be done

Although we have our own problems north of the border, at least there is a somewhat consistent system of accreditation in Canada. Each provincial government has set up an arms-length degree quality assurance board (the name varies, but the principle is the same). The Ministry of Advanced Education or its equivalent appoints a committee of senior, respected academics from the institutions, and usually has a bureaucrat ‘observer’ on the committee who ensures the rules are followed. All institutions have to submit new degree proposals and show that they meet provincial standards, which include financial and long-term sustainability. In particular institutions are required to show that they have followed a proper quality assurance process in developing the degree proposal. Most proposals have been thoroughly vetted internally before they reach the committee.The more established universities then get much lighter oversight than a new institution.  Canada though has almost no for-profit universities and those that have tried to set up have run into real difficulties, especially regarding the financial sustainability criterion, which are deliberately rigorous. The aim though is to prevent institutions enrolling students then closing down or disappearing before the students qualify.

However, inter-provincial accreditation, especially for online courses, remains a major problem in Canada. Alberta and British Columbia have an effective agreement that enables transfer of credit and hence student mobility between the two provinces (a BC Minister once famously proclaimed Alberta’s Athabasca University ‘BC’s open university,’ much to the chagrin of BC’s Thompson Rivers University, which operates the BC Open University). However, transfer of credits between students with credits from an institution in one province to an institution in another province is still extremely bureaucratic and difficult in most cases.

In practice, students don’t care about provincial or state boundaries. Athabasca University claims that up to 40% of its students come from Ontario, for instance. The futility of trying to stop students in Minnesota from taking ‘free’ MOOCs from Stanford in California was so obvious that the ban was removed in less than 24 hours. What students do care about though is the quality of the online program. However, as long as each province or state has a rigorous process for accrediting programs and institutions, the acceptance across provinces or states of online courses from ‘approved’ institutions should be automatic.

Furthermore, problems remain in both Canada and the USA if students want to start taking online courses from an institution out of state or province then use that for advancement by transferring to a local university. The answer of course is more flexible credit transfer arrangements, more flexible prior learning assessment, and challenge exams, where students can demonstrate their learning without having to work through courses they have already taken elsewhere. Even some of the more prestigious research universities in Canada are realising that they need to be more flexible if they are to attract lifelong learners, for instance. Thus it’s as much up to the institutions as the regulators to ensure there is some flexibility in the system for students taking out of state or out of province online courses.

Yes, there needs to be sensible protections against fraud and fly-by-night online operators, but too often the restrictions, regulations and barriers are steeped in practices that no longer apply in an open, knowledge-based society. Every institution should be examining the structure of its courses, its admission requirements, its arrangements for credit transfer and prior learning assessment, and its strategy for lifelong learning, if it is to be fit for purpose in the 21st century. It is not an issue just of online learning.

Further reading

U.S. Network for Education Information. (2011). Accreditation and quality assurance. Washington, DC: U.S. Department of Education.

Re.Vica’s ‘Accreditation in the US‘ and ‘Accreditation of Higher Education Institutions in the USA’ (pdf)

Barriers to inter-state accreditation of online courses in the USA

Has the credit hour become a relic?

What’s a Credit Worth?

Zemsky, R. (2009) Making Reform Work: The Case for Transforming American Higher Education Chapel Hill NC: Rutgers University Press

A different standard for accrediting online programs?

Lederman, D. (2011) Mend it, Don’t End It, Inside Higher Education, February 4



Can web 2.0 tools be legally used for education in Canada?

I raise this as a result of an interesting question from Ron Richard,of Meritus University, Canada. Ron asked Tony Vincent, who runs the excellent Learning in Hand site, and myself:

I have recently been researching some web-based resources for our faculty, who teach exclusively online, but who do not venture much outside the limited set of tools provided by our LMS. To this end I was pleased to read on Tony Bates’ web site …. about Learning in Hand and the many resources you have collected therein.

One of the issues that has come to my attention as I read about cloud computing and web applications (an area I am specifically looking into) is privacy and copyright. I would like your take on what I have found to be a pervasive component of many agreements that I see between the user and the web application when they sign that EULA. Here is a section, for example from the agreement with PaperRater, which you (Tony Vincent) have at the top of the list of recommended web apps:

‘By submitting Material to the Web Site, you agree to grant the Company, its agents, affiliates, representatives, licensors, and licensees, a worldwide, irrevocable, nonexclusive, perpetual, royalty-free right (including moral rights) and license to copy, modify, translate, publish, disclose, transfer, assign, sell, and distribute said Material in any form now known or hereafter developed, for any purpose without limitation, and without any obligation of notice, attribution, or compensation to you or another.’

Now I am not suggesting that you should be responsible for every EULA out there, not is it your responsibility to warn people who should occasionally read their own contracts about this sort of thing. Google has a very similar worded section buried in their EULA that grants them access to use in a similar way every email or Google doc you create or receive, which you agree to whenever you sign up for a new account.

What I am wondering, however, is, based on your far more extensive use of such tools than I, do you feel there is any danger or cause for alarm in using software that explicitly claims rights over student work the moment they use the software?

Tony Vincent replied:

Your concerns are certainly legitimate.  I just learned of PaperRater today and added it to my bookmarks (that list is not my top web apps, just my recently bookmarked). I was wondering as I was testing it out where the text I pasted into it would go. Would it appear elsewhere?  I was hoping not. With other web apps, like Blabberize for instance, student submissions can pop up all over the internet by others who embed it.  Usually this is what we want in education–students to create products that are of value to others.  I think the cause for alarm comes from when student work might be shared or copied when they don’t want it to be.  For instance, if a personal reflection typed into Google Docs was somehow made available publicly when the public was not the intended audience.

I haven’t heard of a web app or cloud computing solution cause copyright and privacy problems for schools (yet). I think that is in part because these sites use EULAs that are all encompassing “just in case” and don’t really intend to copy/modify/transfer/etc. the submitted work.  I also think teachers tend to be selective in what web apps they use.  The copyright and privacy implications are definitely things teachers and students need to know about.  I wonder how many teachers even know what a EULA is…?  This would be a good topic for a blog post. 🙂

Here is my reply:

Ron raises an excellent point. First, I should point out that I am not a legal expert. The best person on this topic in Canada is Professor Wesley Wark, Graduate school of Public and International Affairs, University of Ottawa. So my comments should be seen in this context.

The University of British Columbia requires faculty to warn their students  about security and privacy issues if their students are required to use web 2.0 or social media for study purposes. (In other words, it does not forbid faculty to use social media or web 2.0 tools – almost impossible to do in a university, anyway – but does place an obligation on them to advise students of the risks – I think this is correct – anyone from UBC willing to clarify or confirm this?). UBC also provides through a program called ‘Digital tattoo‘ education for students about their web footprint and the implications for security and privacy.

There is a particular issue for Canadian students here. Data located on ‘foreign’ servers are not subject to the same data privacy laws that protect Canadian students.  The U.S. Patriot Act cuts across many privacy requirements for Canadian students, so the concern is that if student data is held on a server in the USA as a result of requirements for study at a Canadian university, and the US government uses that information in a way that is contrary to Canada’s privacy laws, the university could be sued for breach of privacy.  What if a company running a server farm in India decided to sell student data to a commercial organization? There are also issues such as security of data (e.g., what happens to teaching materials or research results stored on an external server if the company hosting the server goes bankrupt?), and ‘quality control’, (e.g., ‘naive’ teachers exposing students to unreliable or educationally inappropriate applications of technology). Recently, there was a recent report on Avatar Rape in Second Life. Second Life is an ‘open’ community – so what happens when a student using Second Life for study purposes is abused by someone from outside the university’s community?

Many of these issues can be addressed by using common sense (not always prevalent though in faculty or students), and the same rules or procedures that apply to campus-based students can be applied just as well to online environments in most cases. Most universities have codes of conduct for online behaviour. However, as in the Second Life example, there are situations where on-campus or ‘within institution’ online policies and procedures won’t apply or work. Also no university wants to be the first ‘test case’ on an issue that is likely to go as far as the Supreme Court of Canada, with all the inherent costs and risks.

Security of student data and privacy is a growing issue and governments in Canada are beginning to take it seriously. For instance, Alberta’s Auditor-General has required the Alberta government to put in place in all its post-secondary educational institutions an IT management governance protocol that ensures that each institution has procedures and policies to protect student (and staff) data, and a clear line management responsibility for security. Vancouver Community College is currently negotiating with the BC Privacy Commissioner a set of protocols about what is and is not acceptable in terms of web 2.0 applications regarding student privacy, and the rest of the province’s educational institutions are watching this with considerable interest.

Another possible solution for safeguarding privacy is for institutions or government agencies to negotiate specific agreements with companies such as Google, exempting the institutions from some of the standard requirements in the EULA. Another is to have an ‘inner cloud’ where provinces or states run their own server farms that provide a security filter before connecting to external servers on the World Wide Web, although I don’t know of anyone that has done this yet (at least in North America – China has a similar system for the Internet as a whole, which is a pretty good indication of the likely opposition if this was tried in North America).

Ron added one more spin on the topic:

I was working at the University of Windsor a while back when they were evaluating new LMS systems to install campus-wide (they were the first in the country to go with Sakai, by the way), and one of the issues we had in the early stages of testing and evaluating was whether we would consider allowing an LMS provider to host the service for a year or two until we felt able to get the infrastructure and expertise in place to run it ourselves. Our legal counsel advised us that any such hosting had to ensure all student files and information had to be housed on Canadian soil, for the very same security and Homeland Security issues you mentioned.

The answer to the question posed in the heading is of course, yes – but there are risks. Now if we listened to lawyers nothing would probably ever get done. Their job is to point out risk, and decision-making requires risk to be balanced by potential benefits, and those of us who are using web 2.0 tools know the benefits are huge. I think Vancouver Community College is doing the right thing by working with the BC Privacy Commissioner to reduce risk and clarify the ground rules.

Ron and Tony and I would be really interested to hear more from others – particularly those with a legal background – about this issue. How can we use web 2.0 tools in a practical way while at the same time protecting student data and privacy? Let’s hear from YOU!

Using iPods for teaching and learning

Vincent, T. (2010) Learning in Hand Nebraska

This is one of the best web sites I have seen about using iPods for teaching and learning. Lots of useful tips. The web site also includes help on other handhelds, such as PDAs and netbooks, and access to podcasts on these topics via iTunes.

Thanks again to Richard Elliott’s e-Learning Watch for this.

Latest issue of IRRODL

Mea culpa, but in the preparations for the holiday season, I let slide by my report on the publication of the latest edition (Vol. 10, No. 6) of the always excellent International Review of Research in Open and Distance Learning. The December edition includes articles on the following:

Rory McGreal’s evaluation of the Commonwealth of Learning’s e-Learning Training division

Zawacki-Richter, O., Bäcker, E. and Vogt, S. (2009) Review of Distance Education Research (2000 to 2008): Analysis of Research Areas, Methods, and Authorship Patterns

This very important article examines research published in five distance education journals between 2000 and 2008. Main results:

  • Research in distance education is dominated by studies that focus on interaction and communication patterns in computer-mediated communication, instructional design issues, learner characteristics, and educational technology. In comparison, a very few studies on costs and benefits or policies and management.
  • In terms of research methods, a modest upward trend on a low percentage level for qualitative research methods.
  • More than 80% of all articles were contributed by authors from only five countries: USA, Canada, UK, Australia, and China.
  • A significant trend was found towards more collaboration among researchers in distance education.

There is also a really useful classification of research areas in the article.

I have a few comments about this article.

  • First why did they restrict themselves only to ‘Western’ DE journals? Why did they not look at the Turkish Journal of Open and Distance Learning or the Asian Journal of Distance Education, for instance? It is not surprising that there was a national bias in the journals’ authors, but so there was in the article itself.
  • Little was said about the quality of the research (after the review of preceding literature), other than analysing the balance between quantitative, qualitative and ‘mixed’ approaches. However, you can have really bad quantitative articles and really good qualitative articles and vice versa. As the article noted, the main concern about DE research is its poor quality – too many publications and not enough coherence in the field.
  • Looking at journal publications alone may give an unbalanced view of publications in distance education. For instance, I suspect that there is a far higher proportion of books on strategies, policies and management than there are amongst journal articles. So any thorough review should include books.
  • A lot of ‘distance education’ research does not appear in distance education journals nowadays. A lot appears in journals on e-learning and learning technologies.
  • Now how about an analysis of blogs on distance education and e-learning? Anyone up to it?

Despite my comments this is a really important article.

Brown, A. and Green, T. (2009) Time Students Spend Reading Threaded Discussions in Online Graduate Courses Requiring Asynchronous Participation

Akyol, Z., Garrison, R. and Ozden, M. (2009) Online and blended communities of inquiry: Exploring the developmental and perceptional differences

Veletsianos, G. and Kleanthous, I. (2009) A review of adventure learning What is adventure learning? Online learning programs that focus on adventure and outdoors expeditions – such as following and participating online in an Arctic expedition.

Mishra, A. et al. (2010) Evaluation of the Undergraduate Physics Programme at Indira Gandhi National Open University: A Case Study Good to see a study of teaching science at a distance from the excellent IGNOU.

There is also an insider’s view on The First Doctoral Program in Distance Education in North America by a student,
Dorothy (Willy) Fahlman. This is about Athabasca University’s Ph.D. program.

Lastly (well almost) there is a review by Michael Beaudoin of a recent Sloan Foundation publication that I hadn’t known about but needed to: Online learning as a Strategic Asset, in the form of two reports:

S. McCarthy and R. Samors (2009). Online Learning as a Strategic Asset, Vol. 1: A Resource for Campus Leaders. Washington DC: Association of Public and Land-Grant Universities.

J. Seaman (2009). Online Learning as a Strategic Asset, Vol. 2: The Paradox of Faculty Voices. Washington DC: Association of Public and Land-Grant Universities.

Dang – that’s not all! There are also several interesting reports from the CIDER sessions, also worth reading. Now you know why it’s taken me so long to write this up! So read it – if you can find the time.

Special report on virtual schools

Van Dusen, C. (2009) eSN Special Report: Beyond the Virtual School eSchool News, Nov 1

Because of the volume of stuff that comes through my portal, I don’t usually cover k-12 reports, but I’m including this one because it provides some excellent examples of what I like to call hybrid learning (reduced but not eliminated face-to-face time plus online learning) that could easily be adapted for post-secondary education use. It also looks at some ‘desperate’ schools that are using online learning materials in the classroom because they are short of qualified teachers.

This has prompted me to float an idea that has been bubbling around for some time in my head, to do with very large lecture classes.

We now have initiatives such as Carnegie Mellon’s Open Learning Initiative that develops high quality e-learning material that is designed to be used with local instructors. Carol Twigg’s National Center for Academic Transformation has also been re-designing large lecture classes with increased time being spent by students working online.

Why not go the next step, and have a state/province-wide or national program to develop high quality online materials for first and second year university students on at least a 50-50 model of face-to-face and online learning that can easily be adapted to local needs? (For example, modular, so if a local professor wants to add in something to the program face-to-face an online module can be replaced).

Do we really need Mathematics 101 poorly designed differently from scratch every year by thousands of professors then delivered badly by graduate students? Why not have a well-designed ‘core’ hybrid online program that can then be adapted and modified, supervised and managed by local research professors, with (specially trained) graduate students as online and face-to-face tutors?

Some students may need all the face-to-face teaching they can get; others may manage the whole program online; while others will appreciate the blended model. Some departments may well be happy to take the whole online program; others may want to use only small bits of it; others may want to mix and match with local, face-to-face teaching. All we need to make this happen is for professors in different universities to agree to work together on the initial design. Not much to ask, is it? (Yes, I’m joking.)

Comments, please!