Auditing Distance Education

1. Auditing Distance Education LeBaron Woodyard, Ph.D Dean, Academic Affairs Community Colleges Internal Auditors Conference May 4, 2017

2. Topics • DE Definitions (CCR title 5, 55200 et seq) • Regular and Effective Contact • DE Attendance Accounting • Hybrid Courses • Residency Determinations • Case Study: San Francisco City College Audit

3. Distance Education: Definition & Application • Instructor and student are separated by distance and interact through technology • CCR title 5, section 55200 • 51% of instruction is distance in lieu of face-to-face • CCR title 5, section 55210 • Distance Education Guidelines 2008 • Subject to requirements that may be imposed by the Americans with Disabilities Act and section 508 of the Rehabilitation Act of 1973, as amended • 42 U.S.C. §12100 et seq and 29 U.S.C. §794d

4. Distance Education: Definition & Application (continued) • Must undergo separate review and approval by the district’s adopted procedures • CCR title 5, section 55206 • Course quality is the same as traditional classroom courses • Determinations about quality must involve faculty. • CCR title 5, section 55202 • District governing boards must ensure “regular and effective contact” • CCR title 5, section 55204

5. Side Note: Regular & Effective ContactCCR title 5, section 55204 Includes: • Group or individual meetings • Orientation & review sessions • Supplemental seminar or study sessions • Field trips • Library workshops • Telephone contact • Correspondence • Voice mail • Email • “other activities” Caveats: • Academic and professional matter pursuant to section 53200 et seq. • Consistent with guidelines issued by the Chancellor pursuant to section 409 of the Procedures and Standing Orders of the Board of Governors

6. DE Attendance Accounting • Most DE courses follow the Alternative Attendance Accounting Procedures • Any course that does not meet on a regular basis regardless of percentage of time will require use of the alternative attendance accounting procedure. • Example: • 90% regularly scheduled • 10% not regularly scheduled

7. “Hybrid” Courses • No official definition of “hybrid course” in California statute or regulation or distance education guidelines • However if less than 51% is at a distance then by deduction the course is a “hybrid course” • College’s must consider the course regularly scheduled time as a whole to determine accounting procedure, the entire course must meet at the same time, all the time.

8. DE and Residency Determinations Issue: • Audit Test 425 – Residency Determination for Credit Courses is a delay for students enrolling in courses through the Online Course Exchange* and may cause potential audit findings for colleges offering those courses if a college accepts another college’s determination and does not determine it themselves. *The Online Course Exchange is a project of the Online Education Initiative

9. DE and Residency Determinations Recommendation: • Clarify statutes and guidelines for residency determination requirements among colleges offering courses in the Online Course Exchange to allow the teaching college to accept the determination of the home college and which will eliminate enrollment delays and not subject the college to an audit exception.

10. DE at San Francisco City College “CCSF can’t prove it taught 16,000 students, must pay $39 million” –San Francisco Chronicle • NOT an indictment of the quality of their distance education program

11. DE at San Francisco City College • Official record keeping in the Learning Management System (LMS) software was not enforced • Classification of “To Be Arranged (TBA)” courses as DE but they were not held to the same standard as a DE course • Not required to use the LMS • Not coordinated with Education Technology Dept • No DE addenda created

12. San Francisco City College January DE Audit • Approximately 3 month process • Pre-work required college to provide DOE with administrative-level access to their LMS prior to first visit • Audited 2014-2015, 2015-2016, and 2016-2017

13. San Francisco City College January DE Audit - Continued • DOE thoroughly examined courses • Found problems with the CCSF use of META courses that contained multiple course record numbers • When DOE could not find a student it was because they were dropped – SFO re-enrolled the students with activity and the grades were restored.

14. San Francisco City College January DE Audit - Continued • DOE thoroughly examined courses (continued) • Explored “substantive interaction” (equivalent to regular and effective contact) • In online discussions looked for faculty prompting • Video FAQs were not adequate • External website vendors did not archive substantive feedback

15. San Francisco City College January DE Audit - Continued • Result • No significant findings • Expedited Final Program Review – no formal report, no rebuttal • Some problems with documentation and substantive interaction

16. THANK YOU LeBaron Woodyard, Ph.D., Dean, Academic Affairs Erin Larson, Specialist in Academic Planning and Development Education Programs and Professional Development Unit Academic Affairs Division California Community Colleges Chancellor’s Office eppdunit@cccco.edu