Competency-Based Education: is it really “Correspondence Education” in disguise? If yes, it might not be eligible for federal funding. Congress largely eliminated Title IV aid for correspondence courses because of widespread abuse.
In December 2017 The Huffington Post published this piece, Risks Of Fraud In Competency-Based Education, written by David Halperin, where he reviews the U.S. Department of Education’s Office of Inspector General report on Competency-Based Education. We’ve posted several excerpts below but suggest you read both the OIG report and the Huffington Post piece. Halperin reminds us that correspondence education cannot be funded by federal Title IV monies unless students have “regular and substantive interaction with the faculty”. He states,
“The Inspector General report found WASC’s oversight of such programs by educational institutions lacking in a number of respects; for example, WASC “did not evaluate whether proposed competency-based education programs were designed to ensure faculty-initiated, regular, and substantive interaction between faculty and students. According to Title IV regulations, programs that are not designed to ensure such interaction should be classified as programs delivered via correspondence, not distance education.”
Such correspondence courses were eliminated by Congress from eligibility for Title IV aid in the early 1990’s after investigations revealed widespread abuses. The blanket ban was modified late in the 1990’s as various interests pushed for eligibility of distance education programs delivered via the Internet. Congress attempted to provide for eligibility of legitimate distance ed programs by distinguishing them from ineligible correspondence programs based on the “regular and substantive interaction with the faculty” that characterized the former.
My expert sees a risk that the new IG report will create pressure to eliminate this test, and the expert believes doing so would “provide an enormous loophole for correspondence programs to sneak back in, and create the next path of least resistance for widespread fraud in Title IV.”
(Halperin goes on to include many quotes from the Higher Education expert, like these below.)
“One of the most effective policy changes implemented at that time was to eliminate the eligibility of correspondence schools for participation in federal student aid programs. In essence, Congress finally figured out that sending a student a book is a far cry from actually teaching that student, and that libraries and universities are entirely different institutions.”
Enthusiastic interest in competency-based education—the idea that certain students in certain disciplines may be able to master content independently with resources and support from institutions—has now emerged as a perfect loophole for the next cycle of student aid fraud in the hand of for-profits. This is partially because policy cheerleaders for competency-based education—the usual suspects at foundations, think-tanks, and start-ups—are promoting what should rightly be viewed as only a piece of the broader higher education infrastructure as a panacea. What may work well for some students in some disciplines at a subset of institutions is being ballyhooed as the universal solution to all the ills of higher ed, mainly because it, just like distance ed was supposed to do 20 years ago, is thought to be a promising solution to escalating costs and limited resources in higher education.
But while competency-based education in the right settings may well be a piece of the bigger access and opportunity puzzle, consider the fact that stripped to its bare essentials, it can be nothing more than a high-tech version of correspondence education: a curriculum, some course content and a bunch of machine-graded multiple-choice tests, this time delivered via the Internet instead of US Mail. It is in this context that an important provision of the 2008 reauthorization of the Higher Education Act—mandating “regular and substantive” interactions with the faculty serves as a last line of defense against the hijacking of competency-based education by fraudsters. Any distance-delivered program that doesn’t satisfy this statutory requirement may, in fact, be nothing but an old-fashioned 1980s-style correspondence program dressed in Internet garb.” [Emphasis added]
If CBE is truly a form of distance or correspondence education, what does this mean for the future of Competency-Based Education Title IV funding?
- Define “faculty”. Could faculty be a robot or computer generated avatar, or maybe a video game or YouTube video? Could “faculty” be artificial intelligence or algorithms? Could “faculty” be the YMCA or local museum or library where a child visits (virtually or in person) to receive credit hours for a competency credit?
- Define “competency” and credit. Is equal weight and equal learning/mastery earned via playing a video game, skateboarding, or virtual learning online vs learning in a classroom over the course of a school year with pen and paper and a face to face real human teacher? How does one define CBE requirements and verify learning has been achieved?
Indeed, the OIG report asks these same questions,
“The desire to support innovation among our member institutions is sometimes in conflict with current regulations and Departmental guidance related to them. The external pressure to support, or at least not impede, innovation is strong from many sectors. During a conference call related to the experimental sites, US Department of Education Undersecretary Ted Mitchell stated that competency-based education is at the heart of its innovation agenda. Despite this, clear and timely guidance related to determining what is expected and, more importantly, regulations to define what is required have not been forthcoming, which presents challenges to accreditors who review these programs. Indeed, the guidance regarding competency-based (particularly direct assessment) education programs, and therefore reviews, has trickled out.- OIG https://www2.ed.gov/about/offices/list/oig/auditreports/fy2016/a05p0013.pdf
This March 2013 Dear Colleague Letter on CBE requirements for Tittle IV funding from the US Department of Education discusses the Higher Education Reconciliation Act of 2005, and states that “Under current regulations, the entire program must be provided by direct assessment.” The 2013 letter also not so subtly hints that it will encourage and inform on the need to change these regulations to fit CBE.
“The Department plans to collaborate with both accrediting agencies and the higher education community to encourage the use of this innovative approach when appropriate, to identify the most promising practices in this arena, and to gather information to inform future policy regarding competency-based education. Currently, the direct assessment authority in the HEA is the mechanism through which title IV, HEA funds can be provided for competency-based education, and we understand that it may not adequately accommodate this educational model. The Department intends to use what we learn from participating institutions to inform future discussions regarding the reauthorization of the HEA. “
The Department got so many funding questions from institutions in response to this letter, USDoE published this 2014 Q&A which also demonstrates the difficulty of CBE.
Will Congress create a loophole for CBE with the current push to reauthorize the Higher Eduction Act?
Remembering Halperin’s warning that Congress will lift the funding ban on correspondence ed, “the IG report will create pressure to eliminate this test, and the expert believes doing so would “provide an enormous loophole for correspondence programs to sneak back in, and create the next path of least resistance for widespread fraud in Title IV.”, is this somewhat prophetic?
S.615 Bennett / Rubio 2018 bill “Higher Education Innovation Act” that would create an alternative authorizer for Higher Ed To establish an alternative, outcomes-based process for authorizing innovative, high-quality higher education providers to participate in programs under title IV of the Higher Education Act of 1965. Part H of title IV of the Higher Education Act of 1965 (20 U.S.C. 1099a et seq.) is amended by adding at the end the following:
“need not meet the requirements described in—
“(i) section 101(a)(5);
“(ii) section 102(b)(1)(A)(ii)(II); or
“(iii) 102(b)(1)(D); and…”
Halperin’s Huffington Post piece gets it right when he says, “the 2008 reauthorization of the Higher Education Act—mandating “regular and substantive” interactions with the faculty serves as a last line of defense against the hijacking of competency-based education by fraudsters. Any distance-delivered program that doesn’t satisfy this statutory requirement may, in fact, be nothing but an old-fashioned 1980s-style correspondence program dressed in Internet garb.”
We hope someone in Congress is listening and protecting students against the CBE fraudsters.
Whether you call it online “personalized learning”, or “proficiency-based learning”, what’s so bad about Competency-Based Education?
You’ll see it is not a partisan issue, rather what’s at stake affects all children and should be a wake up call for parents and educators.
Anthony Cody, Will Competency-Based Learning Rescue the Testocracy?
Karen Effrem, Concerns about Competency Based Education
Peter Greene, What’s so bad about Competency-Based Education?
Michelle Malkin, The Student Data-Mining Scandal Under Our Noses
Parents Across America, Parents raise the edtech alarm
Emily Talmage, What is Proficiency (Competency) Based Learning?
Shane Vander Hart, Five Problems With Shifting to Competency Based Education
Wrench in the Gears, Hoping to Escape Competency-Based Learning
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