A January 2016 Inside Higher Education article highlighted the scrutiny that Western Governors University is getting by the US Office of the Inspector General. This is not new, as the investigation has been underway for almost three years. There is much that is interesting and noteworthy about this investigation, but it all revolves around determining if Western Governors University is compliant with the Higher Education Act of 1965 which distinguishes between collaborative and correspondence course by whether there is “regular and substantive interaction” between the faculty and the students.
Whether you get categorized as one or the other matters mostly because if you get labeled a correspondence program, that changes if and how you can participate in the federal financial aid program. That, of course, impacts whether students depending upon that federal program can afford to go to your school. As such, I would like to focus on that one phrase, “regular and substantive interaction.” I will share a list of observations, questions and proposed considerations; paying special attention to how all of this impacts the pursuit of educational innovation in education.
Where is the definition and explanation of what do we mean by “regular and substantive”?
Nowhere in the Higher Education Act of 1965 is there a clear and substantive definition of “regular and substantive.” Think about that. The fate of a University’s financial model depends upon whether they are compliant with a three-word phrase that is never clearly explained. Someone like the US Office of the Inspector General or the US Department of Education can come in, review your programs, and suddenly decide that you are not compliant.
Where is the review of existing models of education?
I’ve studied at close to twenty Universities, almost all of which would be considered quite traditional schools. I can say definitely that I had plenty of courses and experiences in those programs where there was limited, minimal and sometimes no “regular and substantive interaction” with my professors.
Is an non-interactive lecture substantive?
Keep in mind that even the most fundamental definition of “interaction” is that it is reciprocal. That means that an instructor standing up front, lecturing at a class, without a regular and substantive back and forth exchange is not, by definition, interaction. I have not found a single example of any federal agency pursuing a University for allowing professors to engage in non-interactive lecture as a common practice in their classes. If we are going to have such a standard, we need to apply it universally. Yes, if we are going to truly apply this standard across the board, then instructors who do not have truly interactive classes would seem to be threatening the financial aid status of the University.
What is regular?
Is this multiple times a day, daily, weekly, monthly or something else? Again, this comes back to a lack of clarity. Interview University studies around the United States and I can guarantee you that there are plenty of students who went through entire degree programs with less than twenty or thirty personal, one-on-one exchanges with professors. Where is the regularity in that? If you have ever been through the process of writing a dissertation, had an advisor who took forever to get back to you and you struggled your way through that solitary experience, I wonder if you would define that as “regular” interaction with a professor.
What is substantive and how does it impact grading practices?
Again, this has implications for interactions with students through grading and assessment. Is sending a test through a Scantron machine and sending it back to students substantive interaction? What about the instructor who just grades a paper and provides little to no deep feedback on the student work?
What does this mean for faculty autonomy?
If federal agencies are going to threaten fining Universities over whether this is happening and they were to actually apply this standard universally instead of picking on certain models over others, this would have a huge impact of faculty autonomy. It would be goodbye to faculty just doing their own thing. It could, ironically, lead to more centralized standards and control that are more common in institutions like Western Governors University, many for-profit online schools, and many non-profit online programs that have built similar systems. As with all things, there are affordances and limitations to this, but applying this standard across the board would shake things up. Of course, I see little intent or interest in doing that.
Why do traditional practices and programs get a pass?
While I’ve stated this already in some of the other questions, there is something really important in this question. Why is it that we have not seen any audits of existing programs on the basis of this “regular and substantive” expectation? What does this say about how people are using the policy? What is it really about? Does this have anything to do with academic quality or was it just an effort to maintain or protect a status quo, even though the statement itself can be used to challenge the status quo if it were used equitably?
Does this help educational innovations that truly have promise to increase student learning, engagement, graduation and more?
We know that faculty-student interaction can be an incredibly important factor. There are other really important factors as well. My question is simple. Does this current policy really help? How has it resulted in better outcomes?
Is it time to revise the policy?
Given all these points, might it be time to revise this part of the Higher Education Act of 1965? Perhaps we need new wording and a new vision for promoting and empowering a diversity of pathways to high-quality, high-impact, high-return higher education learning experiences. As it stands, I fear that the current policy and practice only stifles innovation while giving less than promising existing practices a pass.