“Important Updates about Teaching Online in California”


Attending the 2012 Online Teaching Conference: The Many Faces of Online Teaching at Evergreen Valley College was very productive! There were various interesting sessions (for example, Yong Zhao’s presentation titled “When Distance Is Dead: The Implicatiaons of Global and Open Education,” and Denise Castro and Drew Waters’ “Addressing Multiple Learning Styles in the Online Classroom Environment”), but I focused on the one day meeting of all Distance Learning Coordinators. In this brief post, I want to highlight a few of the pertinent online learning issues, regulations and policies discussed in sessions such as Russ Poulin’s “Updates (and Rumors) on Federal Regulations of Distance Education,” and LeBaron Woodyard’s “Distance Education Issues from the Chancellor’s Office’s Perspective.”

Correspondence or Distance Education?

The Department of Education’s accreditation bodies all over the United States are now looking at Distance Learning in more rigorous ways. One of the major concerns is ascertaining that DE courses include regular and substantive interaction between students and the instructor. That regular and substantive interaction is what separates DE courses from “correspondence” courses. Regulations established by the Department of Education in Title 34 subpart A 602.3 defines “correspondence education” as:

(1) Education provided through one or more courses by an institution under which the institution provides instructional materials, by mail or electronic transmission, including examinations on the materials, to students who are separated from the instructor.
(2) Interaction between the instructor and the student is limited, is not regular and substantive, and is primarily initiated by the student.
(3) Correspondence courses are typically self-paced.
(4) Correspondence education is not the same as online education.

DE and correspondence courses are different from one another, and apportioned differently by the state of CA, and therefore accreditation processes must ascertain that DE courses are indeed DE courses. US Department of Education audits can include examination of syllabi, student and faculty interviews, and scrutiny of usage patterns of students and faculty on the Learning Management System. An audit that finds a DE course that needs to be re-classified as correspondence makes the course ineligible to participate in the Title IV financial aid program. Accreditors look for these factors in order to determine if the DE course is actually being delivered as a correspondence course:

  • The LMS has features for participating in discussion boards, chat rooms, and viewing videos, but they are not required.
  • Grading is based upon submission of assignment and tests, not on any online communication/interaction.
  • The course seems like a correspondence course if
  • instructors grade assignments and return them online but are not available to answer questions, or do not periodically send messages to students
  • instructors do not deliver lectures or initiate discussions with students, or tutoring and other resources are not provided to the students
  • syllabi does not describe mandatory or regular substantive interaction between students and instructors
  • students’ posts and discussion forums are student-driven.

State Authorization

On October 29, 2010, the US Department of Education (USDOE) released new “program integrity” regulations. One of those regulations requires that institutions have authorization in each of the individual states where they “operate”; that is, for example, WVC must have authorization from Minnesota in order to deliver online courses to students who live in Minnesota. This regulation stems from concerns about states meeting all requirements for the Federal financial aid that is given to students. Authorization is required to maintain eligibility of the other state to receive federal financial aid. Although this regulation has been vacated, the Federal government is appealing, and thus institutions have until July 1, 2014 to obtain approvals from each of the states where WVC delivers online courses, or to be exempt by each of those states. One approach is to have state by state legislation that establishes reciprocity (you help me, I’ll help you). Further clarification on the requirements are expected in 2013. If the Federal regulation is reinstated, and institutions are found to be non-compliant, they will have to reimburse federal financial aid funds given to students living in non-compliant states.

Last Date of Attendance

An institution uses the last date of a student’s attendance to calculate the amount of Title IV (Financial Aid) that has to be reimbursed to the student. Taking attendance in an online class is receiving a bit of scrutiny. Traditionally, WVC calculates a student’s last date of attendance based on the last day a student enters the secure pass-word protected virtual classroom. The Department of Education has taken the position that documenting the student’s last day of attendance in an online course requires more than just the student’s login into the virtual classroom; it requires “regular engagement“–that is, regular and substantive interaction between the students and faculty in discussion forums, completed assignments and other tools and activities. WVC has taken pre-emptive steps to make sure that it complies with this Department of Education policy; these steps include:

  • Making it clear to online teaching faculty that it is not enough to rely on data generated by the course management system
  • Making sure that all faculty know and enforce the institutional definition of “excessive absences”; the college’s attendance policy can be found on page 183 of the 2011-2012 WVC Catalog:

“Students are expected to attend all sessions of each class. Instructors may drop students from the class if they fail to attend the first class meeting, or when accumulated unexcused hours of absences exceed ten percent of the total number of hours the class meets during the semester. Moreover, an instructor may drop from the class any student who fails to attend at least one class session during the first three weeks of instruction.”

  • Creating and enforcing a last day of attendance (LDS) policy that includes “academic engagement”
  • Enforcing the clear definition of “regular effective contact” between students and instructors; that definition can be found in the WVC Standards and Criteria for Distance Education document
  • Requesting that instructors save the student’s work and document the date the student stopped attending the virtual classroom

Here is a sample of an effective last day of attendance policy:

  • When a student has not participated in discussions or other forms of communication, and/or has not submitted assignments for two consecutive weeks, the instructor will attempt to contact the student and notify him/her that he/she has 5 days to complete the missing work, if not, he/she will be dropped from the course.
  • The instructor documents and saves the students’ work until the point of dropping the student from the course.

Early in the fall, when all faculty return, there will be several opportunities to learn more about this important information.


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