{"id":7540,"date":"2017-10-16T00:00:00","date_gmt":"2017-10-16T04:00:00","guid":{"rendered":"http:\/\/aurora-institute.org\/blog\/cw_post\/the-wgu-audit-the-fine-print\/"},"modified":"2020-02-27T14:46:25","modified_gmt":"2020-02-27T19:46:25","slug":"the-wgu-audit-the-fine-print","status":"publish","type":"cw_post","link":"https:\/\/aurora-institute.org\/cw_post\/the-wgu-audit-the-fine-print\/","title":{"rendered":"The WGU Audit: The Fine Print"},"content":{"rendered":"

\"\"This post originally appeared at the Christensen Institute<\/a> on October 13, 2017.<\/em><\/p>\n

The Department of Education\u2019s audit of Western Governors University (WGU) has grabbed lots of headlines. The audit\u2019s methodology calls into question the nature of\u00a0what it means to be an educator<\/a>, its conclusions forestall the\u00a0potential of technology<\/a>\u00a0to improve higher education outcomes, and it ludicrously recommends that WGU receive the\u00a0biggest fine in the history<\/a>\u00a0of the Department.<\/p>\n

Secretary DeVos will likely reject the Office of the Inspector General\u2019s (OIG) recommendations. But the Secretary also should push back against the troubling assumptions written into the fine print of the 93-page audit.<\/p>\n

Accreditors determine who faculty are\u2014but the OIG defines \u2018instructors\u2019?<\/strong><\/p>\n

The audit sets an alarming precedent regarding who determines the appropriateness of instructional models for online programs.<\/p>\n

Accreditation is by no means a perfect system, but accreditors have traditionally\u2014and legally\u2014had responsibility for determining whether an institution\u2019s instructional model is appropriate to its mission, academic offerings, and student body. The accrediting body, in WGU\u2019s case\u00a0the Northwest Commission<\/a>, is responsible for evaluating the faculty\u2019s qualifications, as well as curriculum design and quality. The audit itself notes: \u201cNorthwest Commission accredited Western Governors University\u2019s educational programs as distance education programs. It did not recognize any of the programs as being offered by correspondence.\u201d<\/p>\n

The Northwest Commission likely found WGU to be a distance education program\u2014offering regular and substantive interaction with instructors\u2014in part because WGU students are required to have near-weekly interaction with their student mentors, who the Commission considers to be part of the WGU faculty. In its audit, the OIG doesn\u2019t dispute this categorization\u2014but it concluded that while student mentors might be faculty, they didn\u2019t count as instructors. Because the definition of distance education in the Higher Education Act requires \u201cregular and substantive interaction with an instructor,\u201d the OIG went on to classify many of WGU\u2019s courses as \u201ccorrespondence courses.\u201d<\/p>\n

The legal distinction between faculty and instructors is blurry at best. When Congress wrote its definition of distance education into the Higher Education Act in 1992, it used the word \u201cinstructor\u201d instead of the word \u201cfaculty\u201d. Neither word is defined in the law\u2014elsewhere in HEA, \u201cinstructor\u201d is mostly used to refer to teachers of foreign languages. In other cases, it seems to be used interchangeably with \u201cfaculty\u201d, as when it addresses the \u201cacademic freedom of instructors involved in the selection of college textbooks.\u201d<\/p>\n

The activities of the OIG undoubtedly reveal a need to clarify the definition of terms like distance education, faculty, and instructor. However, HEA\u2014as written\u2014in no way justifies the leap that the OIG has made in undermining the Northwest Commission\u2019s decision-making on WGU\u2019s instructional model. We certainly haven\u2019t seen the Department of Education previously using its special regulatory powers with regards to instructors to evaluate traditional foreign language departments.<\/p>\n

Regulators are focusing on inputs, not outcomes\u2014and they know it.<\/strong><\/p>\n

One of the most nefarious footnotes in the audit reads: \u201cBecause schools may receive Title IV funds only if they meet certain institutional eligibility requirements, determining whether Western Governors University achieved other goals not mandated by the HEA was outside the scope of our audit.\u201d<\/p>\n

Translation: We don\u2019t regulate the ends, we regulate the means.<\/p>\n

This is an attitude that\u00a0America can no longer afford<\/a>. The traditional \u2018means\u2019 aren\u2019t working. College is more expensive than ever before. A turbulent economy is forcing workers to reskill throughout their careers. We need new, innovative models to address the problems facing a 21st century society by arming students with strong academic outcomes and skills for the labor market.<\/p>\n

WGU is an example of a new model<\/a>\u00a0that could address the needs of today\u2019s students and the modern workforce. It is designed to serve working adults, a population that the traditional model leaves behind. It employs a competency-based model and designs curriculum to make sure that students are learning the skills they need to succeed in the workforce. It hasn\u2019t raised tuition since 2008, and its student loan default rate is\u00a0less than half of the national average<\/a>.<\/p>\n

WGU has a demonstrated track record of success and broad, bipartisan political support. But most institutions pursuing an innovative model weren\u2019t started by 19 state governors, haven\u2019t yet scaled into serving tens of thousands of students, and definitely can\u2019t afford the risk of spending years mired in a bureaucracy that considers student outcomes \u2018outside the scope\u2019. For others aiming to adopt new postsecondary models, the audit\u2019s logic imposes a chilling effect on innovation.<\/p>\n

This is about more than WGU<\/strong><\/p>\n

We are confident that the OIG\u2019s recommendations will be rejected, and business will continue as usual at WGU. But the rest of higher education may not be so lucky. The actions of the OIG demonstrate alarming opposition to innovation and willingness to steamroll accreditors when it comes to nontraditional instructional models. The years and dollars that WGU spent dealing with this audit will serve as a warning\u2014not to those who would seek to abuse the Title IV system, but to those who might innovate to more effectively and affordably serve the needs of students and the workforce. For the sake of\u00a0all that we need higher education to do<\/a>, we hope that Secretary DeVos rejects not just the recommendations of the OIG audit, but also the troubling logic embedded in the fine print.<\/p>\n

See also:<\/strong><\/p>\n