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UCEA.edu: About UCEA : Communities of Practice: Distance Learning: Discussion

Distance Learning

Expert-for-a-Day Discussion: Accreditation
September 29, 2004

The following is a transcript of the September 29, 2004 Expert(s)-for-a-Day Listserv Conversation featuring ACCREDITATION topics with Dr. Randy Rhine and Dr. Marianne Phelps, sponsored by UCEA Distance Learning Community of Practice (DLCoP).



Dear Distance Learning Community of Practice Members,

I am pleased to officially open today’s forum and welcome Dr. Randy Rhine as our accreditation expert from 9 to 3 pm Eastern. (Dr. Marianne Phelps will join us from 3 to 5 pm Eastern and lurking in the background throughout the day, if he has access while he travels in Canada, is Dr. Ron Baker, Deputy Executive Director for the Northwest Commission on Colleges and Universities.) I have received some questions from our membership that I will feed to the listserv throughout the day. Remember that your responses are not moderated and will appear in all 329 of our email boxes shortly after submission and that our experts are NOT expected to answer immediately but as they have time throughout the day. I will prepare an archive of our discussions and post to our section of the UCEA Web site afterwards.

We thank Randy and Marianne for joining us today and remind all of our community that any responses or opinions expressed by these experts are their own, are not binding in anyway, and do not necessarily reflect the official views of any of the six regional accrediting institutions.
--Scott Howell

Brief Biographical Sketches of our Two Experts

Dr. Randy Rhine is the Dean of the College of Professional Studies and Lifelong Learning at Montana State University-Billings and has served as an evaluator for the Northwest Association of Schools and of Colleges and Universities, Commission on Colleges and Universities for seven years and participated on eight campus review teams. He has authored or co-authored three substantive changes documents for new programs or efforts while at MSU-Billings. He also contributed to the 1998 MSU-Billings Self Study, subsequent Focused Interim Visit related to Distance Delivery of Courses, Programs, or Instruction. Randy also organized the Focused Visit and Report related to the Substantive Change for the Offering of Selected Courses of MSU-Billings in Japan and contributed to the 2003 Five Year Campus Visit.

Dr. Marianne R. Phelps is a higher education consultant in the areas of distance education, accreditation, and institutional assessment working both with individual institutions and educational organizations. She is also a member of the Walden University adjunct faculty. Dr. Phelps has significant experience in University administration and academic policy having held a number of posts at George Washington University including University Planning Officer and Associate Provost. Between 1990 and 1993, Dr. Phelps held the position of Vice President of the Council for Postsecondary Education and worked specifically on the 1992 Amendments to the Higher Education Act, which first put teeth into the requirements for recognition of accrediting agencies. Between 1993 and 2001, she was employed by the U.S. Department of Education in several capacities. After the 1998 Reauthorization of the Higher Education Act, which provided the authority for the Distance Education Demonstration Program, she assumed the responsibility for implementing that program. She has also held positions as Chief of Staff to the Assistant Secretary and Director of the Institutional Participation and Oversight Service, which included responsibility for the unit responsible for Departmental recognition of accrediting agencies for federal purposes. For her work in reengineering the Oversight Service, she received the Secretary of Education’s Executive Management award. Dr. Phelps holds a bachelors degree from the University of Michigan and two master’s degrees (University of Wisconsin and George Washington University). She earned her PhD degree from George Washington University.


NOW: RANDY RHINE

Dear DLCOP members, Good morning and thank you for having me participate in this discussion. I have been asked to participate in this discussion in part because of my experience as an accreditation review team member and work on accreditation preparation and issues on my campus at Montana State University-Billings. My responses to questions are based on my opinions and experiences and should not be construed as official positions of the Northwest Commission on Colleges and Universities.

My responses to the questions listed below are as follows:

Q1. What general advice about the accreditation experience would you give continuing education (CE) administrators who are preparing for their next reaccredidation?

R.R. I think it is important for the continuing education unit on any campus to be familiar with the accreditation standards that apply to their area specifically, and how their areas of responsibility are interconnect with other areas of campus and the relation those activities may have to accreditation standards. Many continuing education units are involved in distance delivery of educational programs, contractual relationships to receive or deliver content in partnership with agency not regionally accredited, operate off-campus locations, etc. Do not allow the continuing education unit to be overlooked in the preparation of the campus self study.

Q2. And out of Missouri comes the question, “Q: To what extent are students in online/distance degree programs realizing the importance of Regional accreditation?

R.R. My opinion is that students are going to have a keener interest in whether or not a distance/online degree program in regionally accredited. Financial aid, transfer of credits between institutions, problem resolution, and a host of other issues are important to students. I think regional accreditation standards should provide students with a sense that the institution providing their instruction is responsible and accountable.

Q3. Randy, can you tell us briefly about your role as an evaluator on a team visit—most of us don’t really know what you do, the sequence of events, and especially the kinds of discussions and negotiations that sometimes occur behind the scenes with the rest of the visiting team.

R.R. Being a member of an accreditation team is a very rewarding experience. In the Northwest Region, generally speaking and assuming that you have been through evaluator training, you are contacted by the Commission and asked if you can serve as part of team on certain dates at a certain institution. If you agree, you receive confirmation from the Commission and some time later you will also receive communication from your Team Chair as well as the campus self study and other supporting material from the Commission. In the communication from the Commission you will receive your specific assignment for the review, (specific standards or areas within standards to be reviewed while on campus). Each reviewer is responsible for reading the self study, paying particular attention to the standards they are responsible for on the visit. As I review a self study, I will also examine all the supporting material and visit the campus website. Prior to arrival on campus I submit a list of campus people that I want to visit with while the team is on campus. I generally try to visit with administrator’s key to the standards I am responsible for as well as faculty, staff, community members and boards, and last but certainly not last students. The first night on campus the team has a meeting and specific assignments are established and responsibilities for writing certain sections of the report are made. Generally campus visits are 2.5 days. Over the first two days I conduct interviews and gather information. The team meets at the conclusion of day to discuss the day’s findings share information, and begin to shape the report. On the morning of the last day final recommendations and commendations are prepared by team members, drafts of each section of the report are turned in to the team chair and the exit meeting held with the campus. Sorry for this long answer!

Q4. How does one go about becoming an evaluator and do you recommend that more of us consider getting involved in this process of peer evaluation? Why or why not?

R.R. I believe you are nominated by your liaison officer on your campus to go to evaluator training. I suspect you can also volunteer. You then go to evaluator training and hopefully an assignment soon follows. I think being an evaluator has had a significant impact on my capabilities and ability to serve my institution. I think it is also a great way to give something back to our profession and I highly recommend becoming involved with your regional association.

Q5. Also, how much responsibility does CE really assume in the accreditation process for academic programs that they host and provide logistical support, (e.g. registration, advisement, financial aid, etc.) in partnership with the academic programs on our campuses that prepare the curriculum and authorize the instructors. Are evaluators really looking to the academic department chairs for answers about student learning outcomes for these outreach programs or CE administrators or both?

R.R. My perspective, the relationship between the CE unit and the academic programs that it works with/for should be defined, understood by both parties, and functioning according to the policies and procedures established for the unit or campus CE activities. The appropriate reviews and processes should be reflected in campus policy and consistent with the applicable accreditation standards.

Q6. With respect to NWCCU Policy A-6, Contractual Relationships with Organizations not Regionally Accredited, I am not sure this is a “hot accreditation topic”, but the last couple of accreditation teams I have served on have been asked to keep this policy in mind as we conducted our review. In my experience, institutions are becoming more entrepreneurial and there are more and more opportunities to partner with other institutions of higher education (public and private, and out of country), public and private organizations, and a host of other content and service providers. Policy A-6 recognizes that these opportunities are out there, may be appropriate for your institution, and provides the accreditation framework for review and operation of these kinds of relationships.

R.R. With respect to NWCCU Policy A-6, Contractual Relationships with Organizations not Regionally Accredited, I am not sure this is a “hot accreditation topic”, but the last couple of accreditation teams I have served on have been asked to keep this policy in mind as we conducted our review. In my experience, institutions are becoming more entrepreneurial and there are more and more opportunities to partner with other institutions of higher education (public and private, and out of country), public and private organizations, and a host of other content and service providers. Policy A-6 recognizes that these opportunities are out there, may be appropriate for your institution, and provides the accreditation framework for review and operation of these kinds of relationships.

Q7. My opinion is that you are better served as a campus in the self study and review process by disclosing issues and discussing your current effort to resolve them rather than hoping that someone might not notice the issue during the campus visit. Again, this is just my opinion, but generally surprises are best left to birthdays and Christmas.

R.R. My opinion is that you are better served as a campus in the self study and review process by disclosing issues and discussing your current effort to resolve them rather than hoping that someone might not notice the issue during the campus visit. Again, this is just my opinion, but generally surprises are best left to birthdays and Christmas.

Q8. Careful review of the draft report is critical. At some point after the visit and prior to the final report going to the Commission for consideration a campus will receive a draft of the report for review. The review of the draft report by the campus is not an opportunity for the campus to edit the report or dispute the findings of the review committee, however, it is an opportunity to address factual errors.

R.R. Careful review of the draft report is critical. At some point after the visit and prior to the final report going to the Commission for consideration a campus will receive a draft of the report for review. The review of the draft report by the campus is not an opportunity for the campus to edit the report or dispute the findings of the review committee, however, it is an opportunity to address factual errors.

Q9. My experience has been that each visit has been somewhat unique. Though there are obviously many similarities between campuses, each has evolved and operates in a unique context. Experiencing the different contexts that institutions operate within is one of the great benefits of being an evaluator.

R.R. My experience has been that each visit has been somewhat unique. Though there are obviously many similarities between campuses, each has evolved and operates in a unique context. Experiencing the different contexts that institutions operate within is one of the great benefits of being an evaluator.

Q10. My opinion is that 10 years is probably too long between self studies and campus visits. I would vote for a process that is more on-going, perhaps linking the regional accreditation bodies more closely with the strategic planning and review process on campus.

R.R. My opinion is that 10 years is probably too long between self studies and campus visits. I would vote for a process that is more on-going, perhaps linking the regional accreditation bodies more closely with the strategic planning and review process on campus.

Q11. When planning new online programs, at what point in time should the review or substantive change process be invoked? Is it once the program is fully developed? What, in general, are the accreditation issues to address in moving present programs to an online delivery system?

R.R. Though I am not that familiar with the substantive change policies of all the regional accreditation bodies, If this is a completely new effort, notification of the regional association early in the process is appropriate. The timing may also depends on where an institution is with internal and state levels of authorization. I often use the Northwest policy on substantive change as an outline to guide the development process of new programs or efforts. With respect to moving existing programs to online delivery, the accreditation issues will be presented in the standards and will probably not be too far from the issues of operating a program on campus.

Q12. Are there different levels of substantive change and if so, how does that impact accreditation? Do evaluators like you get assigned to review proposed changes or is this something that the Commission handles?

R.R. There can be different levels of substantive change (major or minor), I have been involved in reviewing changes that are incorporated into or happen as part of the review associated with a campus self study. I have not been a reviewer involved in a visit related to a singular substantive change.

Q13. Do you happen to know what happened to the "seat hours" requirements for learning and what is the generally accepted formula for figuring out "time in course" per credit? Are there any standards used by evaluators right now?

R.R. Outcomes assessment. In the virtual classroom, seat time is not a relevant concept. There are good strategies to measure performance in the virtual space and those will help.

Q14. Any good accreditation stories or anecdotes that you dare share—even if it is doesn’t necessarily have much to do with our own continuing education about accreditation? We all promise to not speculate or read more into any stories than we should.

R.R. Best not to comment too much. Best advice, use the process as intended and realize that the folks coming to your campus live on a campus somewhere in your region. My guess is that by the time you finish the self study process you will know what your issues are and will either be dealing with them directly or planning a solution.

NOW: MARIANNE PHELPS (MP) joins us…

Q15. What does the federal government think is its role in holding institutions of continuing and distance education accountable?

M.P. Except for grant programs, such as FIPSE, the only interest of the federal government is insuring the integrity of the federal student aid programs. The Higher Education Act of 1965 as amended (and now under consideration for reauthorization) provides the framework institutions must adhere to in order to become and stay eligible for federal student aid. The regulations implementing the Act provide the detailed requirements. Currently, the approach to accountability is to limit the amount of distance education an institution can provide and still maintain its eligibility to 50% of courses or 50% of students. Institutions that offer education by correspondence are not eligible at all. This limitation was passed in the 1992 Amendments. I don't believe there are any limitations on continuing education as long as at least 50% of it is provided onground.

The Distance Education Demonstration Program was authorized in the 1998 Amendments. I provides waivers of the 50% rules and some other regulations to schools that are accepted as participants in that program. So, there are currently a few schools that provide more than 50% of their courses via distance education (correspondence excluded) that are participating in federal student aid programs.

Q16. How does accreditation—present or reformed—fit into any changes that are suggested.

M.P. Since 1952 the federal government has relied on accrediting agencies to "certify" the quality of institutions that participate in federal student aid and other federal programs. This still is the case. However, as time has passed the Congress has added more and more to the requirements accrediting associations would have to meet in order to be eligible. In 1998, it passed something that said accrediting agencies must have distance education included in it's scope of accreditation. Secretarial approval is required of each association's scope so there was a process, not at all onerous to facilitate this. The legislation currently under consideration for reauthorization of the HEA would add additional requirements. Off hand I can't remember for sure what specifically is under consideration, but if I have time in the course of the two hours I'm on, I'll try to research this.

Q17. How have the “Best Practices for Electronically Offered Degree and Certificate Programs” that you helped develop assist institutions like ours improve? Any changes proposed or additional practices to be appended to these best practices? (We have heard WICHE has been asked to develop another set of standards, e.g. student services, for a client.)

M.P. I think Sally Johnstone has lots of testimonials as to their value -- me only a few. However, I think they have been very helpful in two ways. They represented the best thinking about those attributes of electronically offered programs that were important to insuring program quality was sufficient and that the programs were offered with integrity. (I used the past tense here, because it's likely that practice has now exceeded the "best practices" developed in 2001 in some respects.) As a result, they were useful to educators who were developing and changing programs. They were also useful and continue to be useful in helping to educate those individuals who serve as reviewers. The cadre of individuals expert in this area still is not large enough to insure they will understand some of the differences between online and on ground programs. The best practices offer a roadmap for evaluation.

Q18. Can you tell us more about CHEA and C-RAC and what they are doing to hold the accrediting agencies themselves more accountable and promote more consistency across them?

M.P. I can't really speak to CHEA except to say that they have been working on changing their standards for recognition. I don't know that increasing accountability is one of the goals, but I believe CHEA and their Committee on Recognition saw ways they could improve their standards, particularly those dealing with assessment in ways that would also improve accreditation.

In terms of C-RAC, the prefatory statement to the "best practices" documents agreed to by all the regionals was the first time there was ever formal agreement among them directed toward consistency. This is difficult because there are real differences among the various associations, and, of course, each thinks their approach is best. There may have been further concrete steps they have taken, but I'm not aware of them. I know there have been continuing discussions.

Q19. How do you accredit and hold accountable the increasing number of VIRTUAL universities who really don’t have a regional headquarters?

M.P. All of them have some physical presence in a state, which authorizes them to operate there. (I purposely did not use the term "to offer education" because in some states they must only be registered as a corporation.) If they are in a state, they are de facto in the area served by one of the regional accrediting associations. Perhaps the question also goes to who can one really examine a "virtual" university. Actually, it's very similar to an onground university. Each has to write a self-study demonstrating how they comply with the association's standards. Then, assuming the self-study is acceptable, a team visits the headquarters and maybe other locations, if they are important in the self-study, evaluates whether the self-study accurately represents the situation, and makes a recommendation concerning what the accrediting action should be along with any observations the team may have concerning the strengths and weaknesses of the university.

Q20. Where does reauthorization and Title IV fit into any proposed changes or reforms impacting accreditation? Any timing guesses?

M.P. Certainly, there will be no bill passed at least until after January when the "new" Congress takes up residency in Washington. It's likely to be later than that. I am hopeful there will be a bill passed in 2005, but depending on the other issues the Congress must deal with, it could be later than that.

The bill currently introduced in the House adds several requirements for accrediting agency recognition. One would require them to determine whether institutions comply with the new transfer of credit provisions also in the legislation. This would require schools to consider credits for transfer earned at any school accredited by a recognized agency. There are other which I'll try to research in the course of 2 hours, if I have time.

Q21. You mentioned the government’s Distance Education Demonstration Program. I heard that this program has not been as successful as anticipated—one or two of the institutions apparently misused federal monies even though everyone thought they were being carefully monitored—and that this unfortunate event with other known diploma mills has triggered further scrutiny and concern by Congress as they undergo Reauthorization. Is this at least partially true?

M.P. One institution was, in fact, removed from the program because personnel there violated student federal aid requirements concerning the timing of drawing down funds. This institution then closed because it was not able or didn't want to pay the liability for the violation established by the Department of Education. There is at least one other I know of that has been found to violate federal regulations. Neither of these institutions could in any sense of the word be considered diploma mills. I don't necessarily think that institutions that offer significant amounts of distance education pose any greater risk to federal funds than any others. All kinds of schools are found to have violated one or more of the student aid requirements. Sometimes this is inadvertent. The regulations are enormously complicated. Sometimes, it's willful as it was in the case of at least the first institutions I mentioned above.

You mentioned the upcoming Reauthorization. Actually, the bill introduced in the House would remove the 50% rules and some others that were previously thought necessary to the integrity of the programs. You are correct, however, that there have been hearings on diploma mills, but this has nothing to do with distance education or the DEMO program.

In terms of the success of the DEMO program, I believe it has been successful as a bridge to the future if nothing else. The staff in the Department have learned what some of the obstacles are to providing aid not so much to distance educational students, but to those who want to offer programs outside of the mold of semesters, quarters, and summer vacations. I don't see a lot of interest in changing this, however. I wish there were.

I hope this is helpful.

Q22. An ERIC document (464 585) written in August, 2000 entitled, ”Distance Education Accreditation Standards According to the Regional Accreditation Commissions” and authored by Vincent E. Flango mentions that one of the topics that the “Best Practices …” didn’t address was “intellectual property issues” for CE/DE authors and instructors. Intellectual property rights continues to be a big issue for most of us administrators working with faculty and I am interested in why it wasn’t included as one of the Best Practices, even if it is just a statement that requires each unit to establish their own policy and adhere to it.

M.P. There were not doubt other things missed. Another criticism I have heard is that the Best Practices don't deal with the need to accommodate disabled students. I think at the time the real concern was getting at those issues that were closely related to distance education, the assumption being that institutions would know those laws and regulations that impacted onground education would also apply in distance education.

Q23. Do you know what the DOE standards are that are “currently in law in its review of the distance learning capacity?” (April 26, 2000 letter from Judith Eaton to Lee Fritschler). Does the DOE have any CE/DE laws in place concerning us that we should also know about in addition to standards, policies, and practices adopted by our accrediting agencies? If so, where can we find them? (Some of us were surprised to hear about the Feds recently fining the University of Phoenix some $9.8 million because they “violated a rule banning pay incentives for recruiters in an effort to boost enrollment.”)

M.P. I think what Judith Eaton was concerned about was that DOE was requiring accrediting agencies to demonstrate that they had been accrediting schools that offer distance education in order for "distance education" to be added to their scope of accreditation. I may not be remembering correctly, however.

Other than the 50% rules, I can't think of any requirements affecting distance learning per se. Federal regulations do govern things like recruiting practices, because there had been lots of abuses in this area in past years. They also govern many other matters such as term structure, which affect institutions that would like to break the straight jacket of the semester or quarter and similar matters. One thing I learned in administering the Distance Education Demonstration Program is that academic administrators and student aid administrators don't converse. There has to be an expert at your institution. There needs to be more communication. You need to take into account what limitations federal regulations may place on your programs.

Several years ago I did a session at a UCEA conference, and the biggest complaint from the participants was that their student aid administrator had told them their students were not eligible for aid. I suspect this is still true and that the reason for this is that continuing education programs frequently involve another pattern which does not fit the financial aid computer system. Good communication among educators and staff is critical.

Q.24 What are your thoughts about bill H.R. 4283 that is before Congress? Overall, is it good? Are their some parts that we should review and provide feedback on to our own elected officials? Apparently it calls for accreditation agencies to make more public or transparent their findings, their evaluators, and so forth; institutions to make more disclosures to students about programs and institutions; and fair credit transfer provisions across institutions among other items. Is this bill part of reauthorization?

M.P. Yes, it is, and you are correct about what it proposes. I pasted the language concerning what accrediting agencies would need to do with respect to distance education. Below is some more language from the bill.

(3) in paragraph (5)--
(A) by amending subparagraph (A) to read as follows:
`(A) success with respect to student achievement in relation to the institution's mission, including, as appropriate, consideration of student academic achievement as determined by the institution (in accordance with standards of the accrediting agency or association) related to each institution's articulation of desired learning outcomes, retention, course and program completion, State licensing examinations, and job placement rates; and other student performance data selected by the institution, particularly data used by the institution to evaluate or strengthen its educational programs, and including thresholds for course completion and job placement rates if the institution offers certificate-granting vocation or technical programs;';
(B) in subparagraph (E), by striking `fiscal and administrative capacity' and inserting `fiscal, administrative, and governance capacity'; and
(C) by amending subparagraph (I) to read as follows:
`(I) record of student complaints received by the agency or association, including those resulting from the process described in section 485(a)(1)(J); and';
(4) by striking `and' at the end of paragraph (7); and
(5) by striking paragraph (8) and inserting the following:
`(8) such agency or association shall make available to the public, and submit to the Secretary, for use in consumer information programs, a summary of agency or association actions, including--
`(A) the award of accreditation or reaccreditation of an institution and any findings made in connection with the accreditation or reaccreditation;
`(B) final denial, withdrawal, suspension, or termination of accreditation, or placement on probation of an institution;
`(C) any other adverse action taken with respect to an institution;
`(D) a list of the individuals who comprise the inspection and review teams for each agency or association, including each individual's name, agency affiliation, and relevant professional experience;
`(E) a description of the agency's or association's process for selecting, training, and evaluating such individuals; and
`(F) the agency's or association's code of conduct for its commissioners and such individuals; and
`(9) such agency or association shall--
`(A) review, during its onsite comprehensive review, the transfer of credit policies of programs and institutions under its accreditation; and
`(B) not adopt or apply standards, policies, or practices that restrict or deny the transfer of credits earned by a student completing courses or programs at other eligible institutions of higher education solely on the basis of the agency or association that accredited such other eligible institution if that agency or association--
`(i) is recognized by the Secretary pursuant to this section to be a reliable authority as to the quality of the education or training offered; and
`(ii) is currently listed by the Secretary pursuant to section 101(c).'.

You asked about my opinion of the Bill. I hate to see a lot more responsibilities placed on accrediting associations. They try to operate on a shoe string so as not to raise costs to institutions. For institutions, I think it is better that accrediting associations do this than government employees, many of whom don't know a lot about higher education. I'd suggest following the progress of the legislation. I don't think it is particularly the time to write at this point since there could be a lot of changes, but i would certainly encourage you to do so when the various bills are being debated in committee. For the House -- Google House of Representatives, then Committee on Education and the Workforce, and I think you will find the bill along with others that have been introduced by Democrats.

Q.25 Any thoughts about the Higher Learning Commission’s requirement that they include, among others, over and above the “Best Practices…” that “The institution assesses student capability to succeed in distance education programs and applies this information to admission and recruiting policies and decisions?” The ability to assess student capability to succeed in CE/DE is a thorny and difficult issue for not just us but higher education too, especially when increased access is called for by educational stakeholders. What do you do then if you identify someone that may not have capability—how do you provide access and accommodate? Furthermore, most of us don’t really know how to assess this capability and there doesn’t appear to be any standards or acceptable instruments for this kind of assessment.

M.P. Again a difficult question! I'd start with how does your institution consider capability in general. This would certainly be different in selective institutions as opposed to open admissions. One important difference is facility with technology -- important to all students, but especially to de students. If your school's mission is more oriented toward access, then I would think you would want to be looking to what student services are needed to give the student a chance at success. Have you looked at what factors seem to be associated with success with your students as opposed to failure? This would be another starting point. I would also talk with someone at HLC or at least ask whomever is your liaison to the Commission to do so.

I said I would try to find the language of the Bill reauthorizing the Higher Education Act, currently under consideration in the House. Here's the language:

`(B) if such agency or association already has or seeks to include within its scope of recognition the evaluation of the quality of institutions or programs offering distance education, such agency or association shall, in addition to meeting the other requirements of this subpart--
`(i) demonstrate to the Secretary that, through application of its standards, procedures, and policies, particularly those required under paragraph (5) of this subsection, the agency or association determines that the quality of instruction and student support services for distance education is comparable to that provided by the institution in its classrooms and on its campuses (or if distance education is the only mode of delivery used by the institution, comparable to the quality of instruction and student support services provided in campus settings); and
`(ii) evaluate how an institution offering distance education ensures the integrity of student participation in its distance education programs;'.
(D) by inserting after `standards' the following: `(including standards to assess the quality of distance education that are comparable to the standards used for face-to-face classroom instruction)';

This is bill language which dumps in only the new language and references other provisions that are not available, but this should give you a good idea of what would be required of institutions to comply.

If you would like a little more guidance re: how to stay up to date with the legislation, email me at mrphelps@starpower.net, and I'll get something to you. Realizing I am on a list serve and more than one person might ask, I'll respond to whatever list of people who have asked in two weeks -- hoping to include all of those who are interested.

 
 

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