COLO Compass | Sustaining Online Learning Takes Evidence Inside and Out
COLO Compass: Evidence and practical direction for chief online learning officers.

By Julie Uranis, Ph.D.
National Distance Learning Week runs November 2 through 6, and one of USDLA’s themes this year is the “Sustainable Future of Distance Education.” For those responsible for online enterprises, sustainability means having the financial resources, operational capacity, and institutional support to continue serving learners.
UPCEA’s Hallmarks of Excellence in Digital Learning Enterprises treat institutional sustainability as a matter of leadership and advocacy. Hallmark 1, Internal Advocacy and Leadership Within the Institution, names sustainability and resource stewardship among its major themes and describes online leaders as interpreters of a vision of higher education increasingly defined by others, including policymakers, legislators, technologies, and students themselves. Hallmark 6, External Advocacy and Leadership Beyond the Institution, carries that work beyond the institution, to legislators, regulators, and the public.
Someone is going to ask what online costs
Georgia made the cost question concrete this year. The state Senate proposed funding online credit hours at a lower rate than in-person hours, cutting $123.5 million from the University System of Georgia. Negotiations with the House scaled that back, but the signed budget still reduced the system’s teaching funding by $34.2 million for online courses. The Senate also established a Study Committee on Higher Education Funding to review the state’s funding formulas and report its findings later this year.
The evidence doesn’t support treating online instruction as inherently cheaper. In WCET’s 2024 survey, no cost category had a majority of respondents reporting lower costs online, and only 10.9% reported a connection between the price of distance education and its cost. A Texas review published in 2019 found that 91.1% of surveyed institutions did not separately track online and campus expenditures.
That gap creates a problem for institutional leaders when legislators and governing boards begin questioning online education’s costs. A useful starting point is a cost map that distinguishes expenses attributable directly to online instruction from shared services and institution-wide infrastructure. Where a digital learning unit administers technologies used across the university, its budget should not automatically become the sole measure of what online instruction costs. Institutions need defensible methods for allocating shared expenses and reliable data on the relationship between costs, revenue, and student outcomes. The same accounting should extend to AI. Reduced staff time may represent greater capacity rather than direct savings, and institutions also need to account for licensing, governance, and implementation costs.
UPCEA’s 2026 Benchmarking Online Enterprises (BOnES) study points to another distortion. Online units often fund services the whole campus uses, such as LMS administration and the help desk, which can inflate online cost figures before anyone compares modalities. Median enterprise revenue reached $16 million this year, yet 23% of enterprises expect a budget cut next year. Leaders should stress-test revenue and enrollment projections against adverse scenarios before a cut arrives.
Hallmark 6 treats external advocacy as a leadership responsibility. When new legislation or regulation focuses on digital learning, the Hallmark names the COLO as the institution’s subject-matter authority, distinct from others who represent the institution on broader issues. It advises building relationships with legislators and regulators before those discussions begin. By the time a budget proposal reaches the Senate floor, the chance to shape its underlying assumption has mostly passed. Georgia’s study committee gives COLOs there a second opening before it wraps up, and other states may start studies of their own. Hallmark 6 is also clear that messaging alone won’t carry the argument. The case depends on whether what an institution does matches what regulators expect and the learner outcomes it can show.
As noted in Hallmark 7, Professionalism, Ethics, and Stewardship, leaders should communicate honestly and explain how their decisions are made. Rigorous cost data may show online costing about the same as campus instruction, which raises its own questions about what online students are charged. A COLO who builds this evidence has to be prepared to share it whatever it shows.
The infrastructure gap behind online quality
The 2026 Inside Higher Ed/Hanover survey of chief academic officers suggests the strain reaches beyond cost. Sixty-three percent of provosts expressed confidence in the quality of their online and hybrid courses, but only 35% described their technology infrastructure for nondegree credentials as robust, and fewer than half (47%) said they had the resources needed to carry out institutional initiatives.
Strong online programs still run on institutional systems designed mostly around residential students. When an adviser can’t see LMS activity, or the financial aid office learns that a student stopped participating only after the term ends, a well-designed course can’t make up the difference. Hallmark 1 asks online leaders to coordinate across academic, administrative, and technology functions, and that coordination has to reach these offices.
Austin Community College is working on this problem across the whole institution. With an $875,000 grant from the Trellis Foundation, the college is building a Digital Twin platform that uses AI and real-time data to bring academic, financial aid, advising, and basic-needs information about each student into one view. ACC began rolling out an initial version of the platform to approximately 46,000 active credit students this fall, with additional functionality planned for spring 2027. ACC’s advisers carry caseloads of 500 to 600 students, and the platform is meant to help them find the students who need attention before problems escalate. The project isn’t aimed at online learners specifically. Online students rely on the same advising, aid, and records systems as everyone else, and those systems have to work together before any of them can serve online learners well.
Financial aid fraud is an institutional risk
In September, Tim Lehmann of Southern New Hampshire University and I wrote about “ghost students,” fake enrollments that fraud rings create with stolen or synthetic identities to collect financial aid and disappear. In December 2025, the U.S. Department of Education reported preventing more than $1 billion in attempted federal student aid fraud that year. The Department identified organized fraud schemes and described additional safeguards, including identity verification requirements for certain aid applicants. California’s community colleges reported approximately $1.8 million in fraudulent federal and state aid disbursements in spring 2026, compared with roughly $6.5 million reported during the first quarter of 2025. State officials pointed to improvements in application screening and fraud detection, although identifying every fraudulent enrollment remains difficult.
Fraud prevention cannot end with identity verification at admission. Institutions also need to identify students who enroll but never participate in any meaningful way. Courses that require meaningful academic participation early in the term can help institutions identify suspicious enrollments. Those activities are most useful when paired with identity verification and financial aid monitoring. Federal Return of Title IV Funds (R2T4) regulations that took effect July 1, 2026, codified longstanding guidance for institutions required to take attendance: they generally must document the date they determine a student has withdrawn no later than 14 days after the student’s last date of attendance in their records. That documentation deadline is separate from the deadlines for completing the R2T4 calculation and returning any unearned aid. For these institutions, documented academic activity helps establish when a student last participated and identifies those who stopped.
Hallmark 1 emphasizes clear executive accountability for digital learning compliance and performance, with the COLO in a central role. It notes that noncompliance can put Title IV eligibility at risk, and it asks online enterprises to keep audit-ready documentation of instructional engagement. Meeting that standard takes the coalition Hallmark 1 describes, across academic affairs, financial aid, institutional research, and IT. Academic participation records and financial aid fraud monitoring cover the same first weeks of the term, but the offices behind them rarely compare notes.
Make the case before someone else does
The chair of Georgia’s Senate Appropriations Committee proposed reducing funding for online courses on the assumption that they cost less to deliver, without a statewide accounting of what they actually cost. Many institutions would struggle to produce that accounting quickly. The information sits across finance, institutional research, academic affairs, IT, and financial aid, and the research cited above suggests few institutions have assembled it. A COLO is well placed to start, with those campus partners at the table. That is the work of internal and external advocacy the Hallmarks describe: having the cost map, the engagement data, and the fraud numbers ready before the next budget proposal arrives.
If you’re a COLO, I hope you’ll join colleagues for the next Strategic Conversation on Financial Models, an UPCEA Coffee Chat by and for Chief Online Learning Officers.
Following the Money: Business Models, Mission, and the Future of Digital Learning Enterprises
November 17, 2026, 2:00 PM ET on Zoom
(registration link provided via UPCEA’s COLO CORe discussion board)
We’ll talk about how funding and organizational structures shape what online units can decide and build, and how COLOs weigh institutional priorities against what the market will support. Come ready to describe how your own unit is funded.
References
Bay, J. (2026, September 11). Can AI help colleges reach struggling students earlier? Inside Higher Ed. https://www.insidehighered.com/news/student-success/academic-life/2026/09/11/can-ai-help-colleges-reach-struggling-students
Davis, V. (2025, January 23). Revisiting the cost and price of distance education. WCET. https://wcet.wiche.edu/frontiers/2025/01/23/revisiting-the-cost-and-price-of-distance-education/
Echelman, A. (2026, May 19). California community colleges crack down on fake students stealing financial aid. CalMatters. https://calmatters.org/education/2026/05/financial-aid-fraud-california/
Etter, B. (2026, August 24). The corner office comes with a view, not a vote: What the 2026 BOnES report reveals about online enterprises’ seat at the table. UPCEA. https://upcea.edu/the-corner-office-comes-with-a-view-not-a-vote-what-the-2026-bones-report-reveals-about-online-enterprises-seat-at-the-table/
Federal Student Aid. (2026, March 27). Implementation of Return of Title IV Funds (R2T4) regulations effective July 1, 2026 [Electronic announcement]. U.S. Department of Education. https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2026-03-27/implementation-return-title-iv-funds-r2t4-regulations-effective-july-1-2026
Georgia College & State University. (2026, March 27). University Senate meeting: Reports from the president and provost. https://frontpage.gcsu.edu/sites/default/files/uploadedfiles/Reports%20-%20US%20%282026-03-27%29%20FINAL.pdf
Georgia General Assembly. (2026). HB 974: General appropriations; State Fiscal Year July 1, 2026–June 30, 2027. https://gov.georgia.gov/document/2026-signed-legislation/hb-974/download
Georgia State Senate. (2026). S.R. 978: Creating the Senate Study Committee on Higher Education Funding. https://www.legis.ga.gov/Legislation/20252026/248254.pdf
IHE Staff. (2026, September 23). Out now: 2026 survey of college and university chief academic officers. Inside Higher Ed. https://www.insidehighered.com/news/quick-takes/2026/09/23/provosts-survey-2026-responsiveness-amid-constraint
Legislative Budget Board. (2019, April). Improve reporting for costs related to online higher education. State of Texas. https://www.lbb.texas.gov/Documents/Publications/Staff_Report/2019/4748_Online_Degrees.pdf
Mancilla, R., Silberman, E., Austin, M., Rutigliano, K., McClelland, S., Miller, D., Dawson, R., Kokkala, I., Suzadail, P., & Parscal, T. (2026). Professionalism, ethics, and stewardship. In J. Uranis & V. Cook (Eds.), Hallmarks of excellence in digital learning enterprises (pp. 88–96). UPCEA. https://upcea.edu/hallmarks-digital
McKenzie, J., Kopp Miller, B., Palsole, S., McCarty, M., Hogue, L., Brafford, C., Shriner, K., Gazi, Y., Westrick, N., Piña, A., Woods, J., Mumphrey, K., & Widmer, J. (2026). External advocacy and leadership beyond the institution. In J. Uranis & V. Cook (Eds.), Hallmarks of excellence in digital learning enterprises (pp. 78–87). UPCEA. https://upcea.edu/hallmarks-digital
Tagami, T. (2026, April 15). Georgia university system increases tuition 1%. Capitol Beat News Service. https://capitol-beat.org/2026/04/georgia-university-system-increases-tuition-1/
United States Distance Learning Association. (2026). National Distance Learning Week. https://usdla.org/events/ndlw/
Uranis, J., & Lehmann, T. (2026, September 10). Academic rigor is a financial defense: What every institutional leader should take from the ghost student problem. UPCEA. https://upcea.edu/academic-rigor-is-a-financial-defense-what-every-institutional-leader-should-take-from-the-ghost-student-problem/
U.S. Department of Education. (2025, December 11). U.S. Department of Education prevents more than $1 billion in federal student aid fraud this year, additional crackdowns expected in 2026 [Press release]. https://www.ed.gov/about/news/press-release/us-department-of-education-prevents-more-1-billion-federal-student-aid-fraud-year-additional-crackdowns-expected-2026
Virasak, M., LaTorre, D., Frasciello, M., Horn, D., Colby, W., Foley, C., Bouchey, B., White, D., & Haines, A. (2026). Internal advocacy and leadership within the institution. In J. Uranis & V. Cook (Eds.), Hallmarks of excellence in digital learning enterprises (pp. 8–20). UPCEA. https://upcea.edu/hallmarks-digital
AI Disclosure
This post was developed with the support of an AI research and writing assistant. AI assistance was used to identify and review relevant sources, verify facts and citations, explore related evidence and examples, develop and revise draft language, and identify claims that warranted additional scrutiny or qualification. When possible, research was verified against primary or authoritative sources.
The topic, editorial direction, argument, source priorities, and decisions about what evidence to include and how to interpret it were guided by the human author. AI-generated research and draft language were reviewed and revised iteratively, including efforts to distinguish documented findings from inference, identify limitations in the available evidence, and avoid claims that extended beyond what the sources could support.
AI-assisted content is treated as draft material rather than final work. Before publication, the author reviewed the analysis, verified material facts and source characterizations, and determined that the conclusions reflect appropriate professional and institutional judgment. The author is responsible for the accuracy and final content of the piece.
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