– Paul Woodburne
An event of potentially earthshaking importance occurred recently. This event was the “Western Governors Title IV” ruling (U.S. Department of Education, Office of Inspector General [USDOE-OIP], 2017). Essentially, this online university has to pay back over $700 million in federal student aid because the school’s online classes were more like ‘correspondence courses’ than good online, ‘distance education’ coursework. A key issue was the 2008 amendment to the Higher Education Act (HEA) of 1965 that required distance education programs to provide “regular and substantive interaction between the students and the instructor.” In this key component of education, the interaction needed to be initiated by the faculty member. From the report (USDOE-OIP, 2017, p. 14-15), regular and substantial interaction in synchronous or asynchronous courses should be:
- Initiated by instructor (who is subject matter expert). Interactions should not always or only be student initiated.
- Planned and outlined in the syllabus. Course materials did not describe regular interaction between students and course mentors and evaluators.
- More than just feedback on assessment. Substantive interactions consisting only of evaluator feedback to students regarding performance task is more characteristic of a correspondence course rather than a course offered through distance education.
The US Department of Education defines distance education as (1) education that uses technology (e.g., the internet, one-way or two-way transmissions through open broadcast and other means, audio conferencing, or DVDs, CD-ROMs, etc., (2) to deliver instruction to students who are separated from the instructor, and (3) to support regular and substantive interaction between the students and the instructor, either synchronously or asynchronously (USDOE-OIP, 2017, p. 13). The technologies must support regular and substantive interaction between the students and the instructor (emphasis mine).
The same regulation defines a correspondence course as “a course for which a school provides instructional materials, including examinations on the materials, to students who are separated from the instructor. Correspondence courses are typically self-paced, with interaction between student and instructor being limited, not regular and substantive, and primarily initiated by the student. Correspondence courses are not distance education” (USDOE-OIP, 2017, p. 14). Schools will be found ineligible if ‘correspondence courses’ exceed 50 percent of the total course offerings, or student enrollment in ‘correspondence programs’ exceeds 50 percent of total enrollment. Auditing of Western Governors University revealed that 62 percent of students were enrolled in 1 or more of the 69 classes that the Department of Education found to be ‘correspondence’ classes (USDOE-OIP, 2017, p. 2).
The issue of prime importance is what constitutes regular and substantive interaction between students and instructor. Per the report, 69 of 102 courses were found to not be designed to offer substantive interaction. Specifically, 32 of the 69 offered no substantive interaction, 27 offered one substantive interaction, and 10 courses offered two substantive interactions (USDOE-OIP, 2017, p. 3). Thus, ‘substantive interaction’ appears to be interpreted as more than two interactions.
The USDOE-OIP (2017) offered both positive and negative definitions of ‘regular and substantive interaction.’ The positive definition is if the syllabus and other course materials “described student interaction with a course mentor or required individual submission of a performance task for which an evaluator provided the student feedback” (p. 16). They did not see the following as substantive interactions between students and instructors:
- Computer-generated feedback. Objective assessments that students submitted for evaluation were seen as problematic because feedback on these objective assessments was computer-generated, was not provided by instructors, and did not facilitate synchronous or asynchronous interaction between students and instructors.
- No faculty/student interactions. Recorded webinars, videos, and readings materials were seen as problematic if the course design materials did not require the students to watch the webinars or videos and then interact with an instructor. Many course outlines stated only that course mentors were available to students for assistance. Had the course design materials indicated that the recorded webinars, videos, and reading materials facilitated synchronous or asynchronous interactions, such as requiring students to contact an instructor or participate in an online discussion moderated by an instructor, these would have been seen as substantive interactions. (USDOE-OIP, 2017, p. 16)
Further, the report concluded that classes that offered regular interaction with only student mentors, and only at the student’s initiation – and that the mentors did not provide instruction – also did not create regular and substantive interactions (USDOE-OIP, 2017, p. 16).
While there is clearly room for some interpretation and overlap between these two types of courses – distance education and correspondence courses – a university concerned with growing enrollments and that espouses quality education ought to be solidly on the side of the angels in this regard.
I have been approached by the major textbook publishers about using their “products and services for teaching” – as I am sure most of us have. These include interactive learning and assessment products, searchable e-textbooks, and “turnkey solutions” that “offer benefits like self-paced courses and outcomes-based learning” (quotes taken from Pearson Higher Education). McGraw-Hill and other publishers have essentially identical products with the same sales pitch.
I have used some of these products, and have found many to be the product of much time, effort, and expense. Much of the material is very well done and adapted to student learning, offering harder problems as easier material is mastered, and the like. These products offer case studies, video clips, newspaper articles, test banks, and homework assignments with randomized problems. The products can be used to offer an entire course, where, after the instructor sets up the structure, homework, reviews, examinations, and the like, the publisher will calculate and assign grades.
Unfortunately, faculty members who use supplemental materials provided by publishers – even when very well done – may create a pedagogically-sound course, which is also a ‘correspondence class,’ thus putting the university at risk for losing federal financial aid funds.
Using the Western Governor’s report as a guide, it appears that, unless there is actual interaction, feedback, ‘call and response,’ and the like, with accompanying faculty-generated feedback, then many exams, videos, and student mentors would NOT qualify a course as sufficiently interactive to be seen as a distance education course. On the other hand, things like announcements, discussion boards, Skype, chats, Zoom sessions, and emails could facilitate regular and substantive interactions.
Looking at my own classes: I record lectures for my online courses in my face-to-face classes using Media Site Live. I also assign required and optional texts and readings. The three exams are all essays. I also assign one or two other written assignments in a course that are essay responses to newspaper or magazine articles. In all instances, I provide specific written responses, which I send back to the students via email and via the US Mail. During a short term, such as 7-week Summer course or a Winter course, in order to accommodate work requirements or family obligations, I allow the students to work at their own pace.
From the discussion above, my online classes could be classified as ‘correspondence’ classes, because the USDOE-OIG says “correspondence courses are typically self-paced, with interaction between the student and instructor being limited, not regular and substantive, and primarily initiated by the student” (USDOE-OIG, 2017, pp. 9 and 14). In addition, the USDOE-OIG does not consider recorded lectures or webinars as contributing to “substantive interactions” if they did not require student to interact with an instructor (USDOE-OIG, 2017, p. 16). Had my course materials indicated that the recorded lectures facilitated synchronous or asynchronous interactions (e.g., required participation in a moderated discussion), the recordings would have been seen as fulfilling the requirement for substantive interaction.
On the other hand, the nature of my exams and feedback suggests that my courses would meet USDOE criteria. I provide significant feedback to exams and assignments by email and the US Mail. Unfortunately, I use my university email rather than D2L’s email, so would not have documentation of this feedback. The same is true for mailed essays.
Section 481(a) of the HEA, and 34 C.F.R. § 668.3 (USDOE-OIG, 2017, p 28) defines minimum instructional time. The USDOE-OIG found that Western Governors did not adequately show that students received the required minimum 30 weeks of instructional time and 24 credit hours in an academic year for their classes (USDOE-OIG, 2017, pp 28-30). In this regard, I think my online classes are fine. I record the actual lectures that I give in my face to face classes, and cover an identical amount of material as I do in a 15-week semester.
For self-preservation, if for no other reason, we need to think deeply about our online classes. We faculty ought to get ahead of this issue and develop a common set of minimum standards for all online classes.
As luck would have it, Clarion University is starting to define quality standards in our online education. Discussions have centered around the frequency of ‘substantive’ interactions. The OIG decision above (USDOE-OIP, 2017, p. 3) criticized Western Governor’s classes for having only 0, 1, or 2 ‘substantive interactions.’ However, it appears that rather than focusing on frequency, we should consider the nature of these interactions.
Other discussion focused on defining substantive interactions. These seem to include written responses to exams and/or quizzes (e.g., beyond “Nice job!”), and moderated Discussion Boards. No precise definition of ‘substantive interaction is given in the Western Governor’s decision. Thus, whether a written response to an exam, a single post, or a response to a student’s post meets the definition of substantive interaction is unclear.
Looking for a definition of regular and substantive that simply focuses on the number of interactions may be too formulaic and inflexible. Perhaps more useful is thinking about these interactions as on a continuum, as given below.
Because my courses are asynchronous, and, particularly in the short courses students can complete the course at their own rate, they would probably be identified as ‘Level 1.’ I do offer meaningful individualized feedback, but only for three exams and a couple of other written assignments. I do have a class that has eight quizzes in lieu of exams and some written assignments, and I write and mail good feedback on these (Level 2).
Closing Thoughts: As a result of the excellent recent workshop on “Regular and Substantive Interactions in Online Classes” organized by Darla Ausel and Suzanne Homan that I attended, I am revising my online classes. While the substance of the modifications is relatively minor, the process of making modifications feels fairly major. I am adding questions that are specific to given recorded lectures that students have to respond to, and I am adding discussion boards, as appropriate.
Principles or Intermediate level Economics courses often focus on abstract theory, and are less open to interpretive discussion. It is hard to discuss how you have dealt with people who have differing marginal rates of time preference, for example. Many people teach economics via math problems. Neither coverage of abstract theory nor math problems lend themselves to discussion boards.
However, a colleague is revamping his online classes by adding discussion boards. His field has many opportunities for good discussion boards, as his area is heavy on discussion and discourse: they can discuss whether they see themselves as a Theory X or Theory Y type of person. Courses in his field are often taught via case studies. This is a natural home for discussion boards. Seeing what he is doing, I can begin to visualize ways of using discussion boards in my classes, especially during the ‘application’ chapters or with respect to supplemental readings.
I have conversed with several people in the course of writing this article. I have been reminded that discussion boards are not the only way to ensure regular and substantive interactions. Skype, Virtual Office Hours, and the chat feature are all ways to help our classes offer regular and substantive interactions between students and faculty, and ensure our classes offer meaningful educational experiences.
Nonetheless, the part that feels most overwhelming stems from the actual mechanics of changing my D2L site. I do not use D2L for non-online classes, and so am unfamiliar with much of its functionality, perhaps even more so after its revision. I’m also overwhelmed by the push to ensure that our class content is accessible to people with disabilities: many documents now need to be updated.
I need and appreciate the support of people who understand the mechanics of D2L better than I do. I really appreciate Darla and Suzanne, who have been and continue to be very supportive and generous with their time.
US Department of Education, Office of Inspector General. (2017, September). Western Governors University was not eligible to participate in the Title IV Programs: Final Audit Report (ED-OIG/A05M0009). Retrieved from https://www2.ed.gov/about/offices/list/oig/auditreports/fy2017/a05m0009.pdf
Paul Woodburne is an associate professor of Economics at Clarion University. He challenges his students to think critically and deeply about economic issues. He has written an intermediate money and banking text that he uses in his classes. About six years ago two freshmen in the dorms heard horror stories about how difficult his classes were and got together for mutual support and study. They found they liked each other and, having graduated and gotten good jobs, are now happily married.