The American Association of Community Colleges (AACC) has filed comments to the U.S. Education Department (ED) on behalf of the community college sector pertaining to a July 24 Notice of Proposed Rulemaking (NPRM) on distance education, Return of Title IV Funds and TRIO.
Among other things, AACC addresses the additional cost and disruptions that would be caused by a proposed requirement that attendance be taken for all distance education courses. Our comments highlight the complexity of attendance-taking in the digital environment, as well as the long-established distance learning platforms that would need to be altered under the regulation.
In our view, ED’s proposed policies in this area do not fairly reflect how colleges already monitor and ensure the academic progress of distance education students. For community colleges, the proposed regulations are basically “a solution in search of a problem.”
AACC also argues against the proposed policy that would eliminate Title IV student aid eligibility for all asynchronous clock-hour courses offered through distance education. This change could have a severe impact on some institutions and flies in the face of processes the campuses and accreditors use to ensure that all programmatic offerings merit the academic credit they carry.
Context and timing
In both cases, ED’s proposals seem primarily directed at the for-profit industry. Furthermore, the rules effectively create a separate, harsher standard for online programs that is out of step with current higher education practice.
If the department wishes to have the regulation take effect next July 1, it must put a final regulation in place by November, as required under the Higher Education Act’s “master calendar.” This does not give ED much time to digest the public comments and modify its proposals accordingly.
Thanks to the field
We thank the many of you who developed your own institutional or state-level comments and submitted them to the department. The comments are compelling and reflect the broad variation of campus practices in these areas. The association hopes that ED officials will meaningfully consider the perspectives of the sector and will have second thoughts about their proposed changes.
