Michael Horn wrote a wonderful summary of his testimony before the Senate Health, Education, Labor, and Pensions Committee about the reauthorization of the Higher Education Reauthorization Act. He focused on barriers to and opportunities for innovation. At the end of his testimony, Senator Lamar Alexander invited the panel, which included Michael Horn, to speak to specific “regulations that are stunting online, competency-based education.” In response that request, I offer the following twelve specifics. I’ve not referenced specific sections in the Higher Education Reauthorization Act (although I did re-read it in preparation for this post) nor am I mentioning specific regulations or policies from regional accreditors. I am offering twelve specific ways to speed innovation with online learning, CBE, and higher education in general. These are barriers that come from explicit aspects of the Higher Education Act and some regional accrediting bodies, but they also include softer but just as significant barriers, those that come from the structure and threat of censure. In fact, when I just re-read the Higher Education Authorization Act, I semi-jokingly commented that it can be summarized in a sentence: “Do not innovate…or else; unless you are Western Governor’s University or a nursing program.” There is more to it, so please don’t click away quite yet. In addition, I’ve include elements that are not present in the regulations now, but adding something related to them could prompt a rapid move forward.
I realize that some of these are controversial, but I share them more as I often do as a consultant for an organization. I am not neutral. My convictions show up, but I do offer this as a menu of items. Depending upon your taste, you will opt for some and not others. If your goal is the speed innovation in these areas, here are twelve ways to do it. As with all policy and regulatory innovations, there are affordances and limitations to every shift, and these are no different. I can’t state this too strongly. These suggestions have significant implications. In fact, some might argue that the risk or danger in implementing some of these is too great. I’ll leave that up to others to discuss for now (although I’m always ready for further conversation and work about this).
1. Clock hours and credit hours
There is already plenty of good discussion about the limitations of the existing system. Where HEA and accreditation agencies leave a little room for experimentation, that is limited right now, leaving people nervous about going through the necessary steps to pursue a format that leaves courses, credits, and clock hours behind. The HEA already has a special provision for nursing schools in this regard. Just take that and extend to across all higher education.
By the way, for organizations with athletic programs, there is need for athletic associations to catch up as well, broadening things well beyond GPA, credit hours, etc. There is already some flexibility, but being more explicit about that flexibility, offering it more broadly, will open doors for innovation.
2. The 200+ page complexity of the current Higher Education Authorization Act plus the overall complexity of federal financial aid in general.
I noticed a Tweet yesterday from a frustrated student, noting that the process for financial aid is more complex than any work she actually gets in pursuit of her college degree. That is a sure sign that something is not right. It needs to be simplified and streamlined to encourage innovation in these new areas. Complex regulations do not provide fertile soil for innovation. It scares off many of the small and medium-sized higher education institutions that want to explore the possibilities of these new areas, and rewards the higher education institutions with deep government and regulatory connections, and likely multiple people on staff dedicated to such matters. Scan the list of most of the direct assessment programs that launched early on, and you will see this is the case with the majority. This is the exact opposite of the trend in the startup world.
Also consider that I happened to help spearhead one of only a few small to medium private liberal arts colleges with a wide scale online operation that is managed almost entirely by internal teams. Why? It is easier to outsource, especially when the regulations are so complex and things are so uncertain. Complexity in the regulations breeds fear and caution…both of which are the enemy of innovation.
3. The HEA dedicated exceptions for Western Governor’s University
A higher education innovation / initiative supported by a group of governors gets a dedicated section in the Higher Education Authorization Act. How does that establish a level playing field for innovation in online learning and competency-based education. While I understand the reasons (at least a couple of them) for initially including it, it is time to remove special consideration for one initiative and offer the same provisions for all IHEs.
4. Limited definitions of programs and certificates.
Open up the definition to allow for non-credit and other forms of training, and you will see a wealth of innovation develop in these areas.
5. Regional accrediting agency expectations of faculty.
I’m a faculty member and I value the professoriate, but there are new models for both education and training that do not depend upon traditional concepts of instructor or the formal credentials normally expected of those people. As long as students are thriving and learning (and there is evidence of as much), why add limitations by being too explicit in expectations about credentials? This doesn’t just inhibit innovation in online learning and competency-based education. It prevents innovations around interdisciplinary education and interesting experiments in alternative higher education. There are also emerging and existing models that do not depend as much on traditional measures of faculty-student ratios. and there are a growing number of exceptionally gifted people who didn’t go the standard routes to achieve excellence. The current regulations often prevent them from teaching the next generation in higher education.
6. The limitation to 35 institutions for direct assessment.
This should probably go without saying, but limiting the direct assessment “experiment” to 35 is slowing down innovation. Let’s open it up.
7. Discouragement of Micro-Innovations
Some individual departments within Universities would love to invest in designing robust competency-based programs, but it isn’t worth the institutional investment to pilot on individual program levels when the experiment is so limited (as in the 35 mentioned above) and with people wondering how the DOE or their regional accreditation agency will treat their innovation. There are many ways to get at this. At minimum, it would be great to create a provision where a program can gain approval to run a micro-innovation (like a CBE program) with limited restrictions for a 4-5 year time period. You can even limit the enrollment if you want. A single voice on this from the DOE and regional accreditation agencies would make it even more promising.
8. Regulations about governance, organizational structures and partnerships need to be adjusted.
Yes, there are certainly examples of suspect partnerships and arrangements, but the explicit or implicit regulations or policies also prevent potentially promising models from being piloted. Who wants to be the next Tiffin University / Ivy Bridge?
9. Transfer Credits
Accreditors expect institutions to have set policies for transfer credit. That makes sense. There are emerging models, like with CBE and micro-credentials, that make it possible to envision a future route toward a degree as coming from piecing together learning evidence and credentials from multiple institutions over time. Leaving more flexibility for such models would allow for these innovations to emerge more easily. There are not strict regulations about transfer credits right now, but I include it because there seems to be something here that could serve as a powerful lever, especially by expanding transfer credit beyond other regionally accredited IHEs.
10. Expand “Higher Education”
The definition of a higher education institution can be broadened today to include so much more than colleges and Universities. There are new experiments and models already in existence. Some are more holistic educational institutions. Others are more training-oriented or focused on workforce development. Right now there are a limited number of regional or national accrediting agencies that give an organization an opportunity to participate in the federal financial aid program. Broaden that to include more oversight agencies or even a model that allows for the organization of a new external agency for accountability.
11. Provisions for Unbundling
There are models now like PelotonU that are providing the student support and much more while having students enroll in one of several existing online CBE programs at Universities. Create provisions for financial aid available to pay for such additional unbundled services (without their needing a formal partnership with an IHE) and we will see some fascinating experiments emerge.
12. Ease the pathway to starting new higher education institutions.
Even while some have predicted that have the higher education institutions in existence today will not be in the next 15 years, there is a counter to that, one that imagines a future of more IHEs than ever, with a wonderfully diverse collection of niche, boutique and alternative higher education models. If you want more innovation, make it easier for people to enter the higher education space. I will be writing more about this example soon, but Wayfinder Academy is one such example. They are working through the state of Oregon and plan to pursue regional accreditation, but there are others with equally compelling and innovative models of online, CBE and higher education in general that are not opening because of the existing complexity and barriers. Anything that can be done to lower the risk and cost of entry will create a new wave of innovation.