UPCEA, alongside OLC, QM, and WCET, is grateful for the opportunity to issue comments and seek guidance on proposed regulations related to the definition of distance education that were part of the recently released proposed regulations by the Department of Education.
Our organizations are pleased that the 2018-9 Negotiated Rulemaking Committee, made up of key stakeholders, came to consensus on the issues presented. Our comments are primarily focused on concerns related to the proposed definition of “distance education” as well as providing support to the proposed changes associated with “academic engagement” and “week of instructional time.” We believe that the proposed changes will improve student access to affordable, high quality educational opportunities, and will improve higher education equity and access.
We greatly appreciate the Department’s desire to “reduce barriers to innovation in the way institutions deliver educational materials and opportunities to students, and assess their knowledge and understanding, while providing reasonable safeguards to limit the risks to students and taxpayers.” The current regulatory definition of “distance education,” which has changed little over the last 25 years, is ill-suited for 21st century learning models. We have been long concerned that a lack of regulatory clarity has had a chilling effect on higher education innovation. While we recognize that technology alone cannot transform higher education, we believe that it can, especially when used in conjunction with distance education and other non-face-to-face modalities, improve access to high quality and affordable educational opportunities for a broader segment of students.
These comments include our support and input on changes for items like:
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Supporting the addition of “academic engagement”
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Distance education
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Technologies for delivery
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Definition of “substantive” interaction
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Definition of “regular” interaction
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Definition of “week of instructional time”
We thank the Department for this opportunity to seek guidance and share our comments. We believe that the proposed changes will improve student access to affordable, high quality educational opportunities and will improve higher education equity and access. We would be very pleased to offer further assistance to the Department and to assist with communications related to final regulations.