Regulatory Noise Stifles, Slows Rise of Competency-Based Learning

Earlier this month, Inside Higher Ed reported on how the Department of Education’s Office of Inspector General is stymying the rise of competency-based learning in higher education—and is at odds with the rest of the Department, which has been enthusiastic about competency-based learning’s potential.

The inspector general released a critical audit of how the Higher Learning Commission, a regional accreditor, considered colleges’ proposals for new competency-based credentials, in particular around whether the programs being approved had “regular and substantive” interaction between faculty members and students in academic programs.

I, along with many others, have pointed out numerous times that this particular regulation makes little sense in today’s world of emerging online, competency-based programs—and we should instead be moving toward outcomes-based judgments around institutions. But the friction is also entirely predictable, as competency-based education simply does not fit into the traditional value network and associated regulatory structures of higher education.

Whenever a disruptive innovation emerges—and online, competency-based learning deployed in the right business model is a disruptive innovation—it doesn’t look as good as existing services according to the old metrics of performance. Disruptions tend to be simpler than existing services; they start by solving undemanding problems. As a result, the sector’s leading organizations often dismiss them because they don’t look terribly good in comparison to the way people have traditionally thought of quality. But they also redefine the notion of what is quality and performance. As such, they don’t fit neatly into existing regulatory structures and often create new ones over time. Judging them by the old regulations can also limit their innovative potential by trapping and confining them to replicate parts of the existing value propositions of the old system rather than deliver on their new value proposition.

For online, competency-based programs, the old metrics are those focused on inputs. These new programs often lack breadth, generally do not do academic research, and they don’t have grassy green quads and traditional libraries. Assessing them based on these criteria along with specifying their faculty members’ academic credentials and course requirements doesn’t make much sense, nor do one-size-fits-all regulations that govern—in the particular case of the inspector general’s audit—how students interact with faculty online, especially given that more interaction in online courses isn’t always better for students. Regulations limiting the geography in which approved programs can serve students are counter-productive as well for a medium that knows no geographic boundaries.

Because competency-based programs are emerging under the governance of existing—and, from their perspective, arcane—regulations around higher education in an effort to gain access to Title IV dollars in the absence of Congressional action, these challenges will continue for some time.

Although innovators will ultimately figure this out and the regulations will likely then cave to the new reality, as has happened in countless other highly regulated sectors where disruption has occurred, there are risks in the years ahead of banking on this approach. First, many students could benefit today from robust competency-based programs—not five years from now. And second, in a desperate attempt to fit into today’s regulatory structure with less friction in order to be eligible for federal dollars, programs could twist and contort themselves and, in the process, lose the unique value propositions that competency-based learning offers—much as has happened in K–12 education as the full-time virtual schools have twisted themselves to fit into antiquated seat-time rules.

At a high level, the solutions to these problems both have challenges today. One is to stay out of the government funding streams, as some online, competency-based programs have tried but struggled to do, or to try to launch a more systematic effort at reform through a reauthorization of the Higher Education Act—an effort that will not be an easy climb with the various lobbying factions that will support the existing order and thus would likely try to stifle innovation.

As a result, progress for competency-based education in higher education will likely come from a combination of all these efforts—but it won’t be straightforward.

See also:

• The Liberal Arts Have a Bright Future in Competency-Based Learning
• Moving Past Summative vs. Formative Assessments

Michael is a co-founder of the Clayton Christensen Institute and serves as the executive director of its education program. He leads a team that educates policymakers and community leaders on the power of disruptive innovation in the K-12 and higher education spheres.