Webinar on New Federal Regulations

Webinar on New Federal
April 18, 2011
Ralph Wolff, President
Senior College Commission, WASC
Please join the audio portion of this webinar at: 800-926-7748
Copies of background materials may be downloaded at:
For assistance with Voice and Web connections please contact:
ReadyTalk Help Desk: 800.843.9166
International Help: 303.209.1600
• Review of Credit Hour Regulation
– Federal Definition
– Institutional Responsibilities
– WASC Responsibilities
• Review of State Authorization Regulations
– State approval requirements
– Complaint provisions
– Distance education state approvals
• Questions
Webinar on New Federal Regulations 4-11
Credit Hour – How We Got Here
• GAO study and IG investigation
• Negotiated rulemaking and final regulation
• Efforts to have federal definition withdrawn or
entire regulation delayed
• Regulation goes into effect July 1, 2011
Webinar on New Federal Regulations 4-11
Federal Definition (600.2)
• Section 34 CFR 600.2
“An amount of work represented in intended learning outcomes
and verified by evidence of student achievement that is an
institutionally established equivalency that reasonably
approximates not less than:
1. One hour of classroom or direct faculty instruction and a
minimum of two hours of out-of-class student work each
week for approximately fifteen weeks for one semester… or
the equivalent amount of work over a different period of
time; or
Webinar on New Federal Regulations 4-11
Section 600.2 (cont.)
2. At least an equivalent amount of work as required in
paragraph (1) of this definition for other academic activities as
established by the institution, including laboratory work,
internships, practica, studio work, and other academic work
leading to the award of credit hours.”
Webinar on New Federal Regulations 4-11
Key Elements
Institutionally established
An amount of work
Represented in intended learning outcomes
Verified by evidence of student achievement
Equivalency that reasonably approximates
1:2 ratio in to out-of-class
(50 minute hour acceptable)
Webinar on New Federal Regulations 4-11
Institutional Responsibilities
• Adopt and apply policy on credit hour
consistent with federal definition
• Implement process for assuring “reliability and
accuracy” of assignment of credit hours across
all credit bearing activities
• Incorporate credit hour review into
comprehensive self-study requirements
Webinar on New Federal Regulations 4-11
WASC Responsibilities
• Adopt policy and procedure for review of institutional
• Demonstrate that a review of credit hours is reflected in
institutional self-studies and comprehensive team reports
• Determine that credit hour assignments “conform to
commonly accepted practice in higher education”
• May use sampling of course credit hour assignments
• Require corrections of deficiencies
• Promptly notifies the Secretary of Education if systemic
noncompliance is found, or significant noncompliance with
one or more programs
Webinar on New Federal Regulations 4-11
Implementation by Institutions
• Assure that credit hour policy is current, applies to all credit
bearing activities, and is consistent with 600.2
• Demonstrate that internal processes exist to assure reliability
and accuracy of credit assignments, such as:
New course/program approval processes
Program review processes
Ongoing syllabi review processes
Communications to deans, department chairs, program directors and
faculty about credit hour criteria
Webinar on New Federal Regulations 4-11
Implementation by WASC
• Will circulate draft policy in mid-May
• Will require:
– That the institution has a credit hour policy consistent with
– That the institution assures the accuracy and reliability of credit
hour assignments through identified processes for all credit
bearing activities
• Will include processes for including credit hour evaluations in all
comprehensive reviews, including a protocol for sampling
• Will require progress reports or special visits to follow up on any
deficiencies, and notification to the Secretary, if needed
• Will consider credit hour assignments in substantive change reviews
Webinar on New Federal Regulations 4-11
Sampling Process
• DCL: “a varied sample of the institution’s degree and non-degree
programs in terms of academic discipline, level, delivery modes,
and types of academic activities.”
• WASC review and sampling process is likely to include:
– Review of institutional polices and credit hour oversight
processes (conducted off-site, if appropriate)
– Sampling of a small number of course syllabi, if possible, a
sample size of 20-30 courses to determine if further review is
– Special attention given to credit assignments in accelerated and
online courses
– Results of policy review and sampling included in team reports
Webinar on New Federal Regulations 4-11
State Authorization – Key Provisions
• State approval to operate and award degrees – for private
institutions only
• State must be able to “receive and act on” complaints – for
public and private institutions
• All online programs must be able to demonstrate they are
operating in accord with state licensing requirements
Webinar on New Federal Regulations 4-11
Approval to Operate
• Section 600.9(a)(1)(i)(A) requires institutions to be authorized
by name through statue, charter, constitution, or action by an
appropriate State agency or State entity
• DCL - Question 3: approval will be accepted if the articles of
incorporation are for the establishment of a postsecondary
institution by name and filed with the Secretary of State
– In California, the BPPE will accept such a filing and WASC accreditation
– In Hawaii, we will work to establish a similar process
Webinar on New Federal Regulations 4-11
Handling of Complaints
• State must have a process to receive and act on complaints
• For public institutions, state entity can be a governing board if
there is sufficient independence from campus
• For private institutions, the State “upon considering a
complaint, may refer it to other appropriate entities, such as
an institution’s accrediting agency, for final resolution.”
• WASC is still obligated to process complaints under Federal
law in accord with established procedures
• In California, BPPE will accept the WASC exemption and refer
complaints to WASC for private institutions
• In Hawaii and Guam, a process will need to be established
Webinar on New Federal Regulations 4-11
Distance Education
• Institutions offering online education are required to have
approval in all states where state law requires approval and to
be able to document that approval is not needed in other
• DCL Question 16 – for 2011-12 good faith efforts to comply
will be accepted
• A useful resource of state requirements:
Webinar on New Federal Regulations 4-11
Additional Actions
• Efforts are still underway to delay implementation or
enforcement of the distance education approval requirement
• Continue to let your Congressional delegation know of the
impact of both regulations
• Provide comments on the draft WASC Policy on Credit Hour
Assignment when it is circulated
• Share information on how you are addressing both new
regulations – a section will be added to the WASC website for
interaction on each area
Webinar on New Federal Regulations 4-11