To be eligible for U.S. federal financial aid funding, colleges and universities offering distance learning programs must satisfy new federal regulations that went into effect in July 2020 and July 2021. In this episode, Russell Poulin joins us to discuss how these requirements have changed and what these changes mean for faculty and institutions offering online classes.
Russ is the Executive Director of the WICHE Cooperative for Educational Technologies (WCET), and the Vice President for Technology Enhanced Education at the Western Interstate Commission for Higher Education.
- Western Interstate Commission for Higher Education (WICHE)
- WICHE Cooperative for Educational Technologies (WCET)
- WCET blog post on Regular and Substantive Interaction
- Questions about Regular and Substantive Interaction that were submitted by WCET to the U.S. Department of Education
- The new Distance Education definition in the Electronic Code of Federal Regulations, section §600.2
- Student Identity Verification requirements in the Electronic Code of Federal Regulations in §602.17(g) & (h)
- International Center for Academic Integrity (ACAI)
- A “Policy Playbook” that includes RSI, Student Identity Verification, and other regulations regarding instruction using digital technologies.
- WCET Frontiers blog
John: To be eligible for U.S. federal financial aid funding, colleges and universities offering distance learning programs must satisfy new federal regulations that went into effect in July 2020 and July 2021. In this episode, we examine how these requirements have changed and what these changes mean for faculty and institutions offering online classes.
John: Thanks for joining us for Tea for Teaching, an informal discussion of innovative and effective practices in teaching and learning.
Rebecca: This podcast series is hosted by John Kane, an economist…
John: …and Rebecca Mushtare, a graphic designer…
Rebecca: …and features guests doing important research and advocacy work to make higher education more inclusive and supportive of all learners..
John: Judie Littlejohn is joining us as a guest host for this episode. Judie is the instructional designer for Genesee Community College, and has been a guest on several of our past episodes.
Judie: And our guest today is Russ Poulin. Russ is the Executive Director of the WICHE Cooperative for Educational Technologies (WCET), and the Vice President for Technology Enhanced Education at the Western Interstate Commission for Higher Education, which, of course is WICHE. Welcome, Russ.
Russell: Oh, it’s so great to be here. Thanks for asking me.
John: Our teas today are:… Russ, are you drinking tea?
Russell: Oh, yes, I’m drinking tea and I live in Longmont, Colorado, which is near Boulder and we have Celestial Seasonings here, and so, I’m drinking Earl Grey that has probiotics in it. That’s a new product for them.
Judie: So you have Earl Grey, but I’ve got Lady Grey black tea from Twinings.
Russell: Oh, very nice!
John: And I have pineapple ginger green tea from the Republic of Tea. We’ve invited you here to discuss the new federal regulations concerning regular and substantive interaction in distance-learning courses. These regulations went into effect in July 2021. We also would like to talk a little bit about the requirements for identity verification that went into effect a year earlier, but before we discuss this, could you tell us a little bit about WCET?
Russell: Oh, I’d love to, and thank you for asking. And so WCET is part of WICHE, the Western Interstate Commission for Higher Education, which is a regional higher education compact focused on the west, but back in 1989, they started WCET to focus on educational technologies, distance ed, online learning – which wasn’t a thing yet then – and, even from the start, we had other states that came in, and now we’ve grown and now we have, members through all 50 states and Canada and even Australia. And our members, are institutions and organizations and corporations interested in the use of distance ed.
Judie: How did WCET become the go-to source for information on regular and substantive interaction?
Russell: Well, we were hearing from members that there was some confusion about exactly what they were supposed to do with this, and that there wasn’t complete clear guidance from the US Department of Education and so Van Davis, who worked at Blackboard at that time, and now works for us here at WCET. And what we did was that we went through all of the guidance, there were some guidance that had been given, and also the findings against several institutions and then tried to put together what is it that they were looking for? What is it that is expected? And then we put together a blog post of our findings, and put that out there, and for like, four or five years, no matter what else we published, that ended up being the top blog post for the year because people were seeing that that was the only place where somebody had compiled this all together and knew what to do. And then in 2019, I was named to the Department of Education’s negotiated rulemaking subcommittee that worked on new rules, and there are people who actually get together and write these rules – you can imagine how exciting that is – and I was part of that and worked on it. And one of the issues that we worked on was this distance education issue and updating this regular and substantive interaction part of it and so you could say I was in the room where it happened! [LAUGHTER]
John: So basically, there was a gap out there that needed to be filled, and there was a lot of concern because of the sanctions that were placed against Western Governors University?
Russell: Yeah, it’d been unclear, and then also yeah, there was these findings against Western Governors University that their courses were all correspondence courses, and that they were expected to pay back – really, when you got to the end of it – it was a billion dollars which they didn’t have in their pockets at the time, and so it really caught the attention of a lot of people and this was a rule that was first written in 1992, had incomplete guidance. It was being administered in different ways and so it was time for a real update and more details about what is it exactly that they’re expecting? And so we worked on that, and we also were able to put in that there’s greater reliance in terms of the relationship between the accrediting agency and the institution, because there were times where it seemed like the auditors were sort of overruling that, and that doesn’t make sense because if you’re meeting what the accreditors want, why is this out of balance?
Judie: So what is needed, then, to differentiate a correspondence course from a credit-bearing online course?
Russell: So, it’s really good to go back and make that distinction and remind people that this is all about federal financial aid and what qualifies for federal financial aid. And they always want to get into, “Well… interaction, the academics, and the pedagogy of it.” Well, okay, put that aside [LAUGHTER] for the moment, we’re talking about, for federal purposes, what qualifies for federal aid and what does not? And the idea was that distance education is something that qualifies for full federal aid, whereas correspondence response education… that you might not get full aid for those courses or if you have enough correspondence students or enough correspondence courses… if over 50% of your students or courses are labeled as correspondence… then your institution is now ineligible for aid, and that’s what happened with Western Governors University. And so, it’s good to be clear, especially as we’re seeing more and more distance ed, hyflex, hybrid sorts of courses about what fits and what does not, and what activities work. We need to know what happens, so that we know that we’re in line, so that we keep our federal financial aid for students.
John: The technology for offering online courses has changed quite a bit since the initial regulations were developed. Under the current revisions, what is meant by interaction in that definition of regular and substantive interaction?
Russell: Yeah, that’s a good point that this rule was written in 1992, prior to online learning [LAUGHTER]. There’s been a lot of changes. But you really do need to parse out the parts of it, and so thanks for asking about the interaction part of it because back in the old definition, prior to July 1, that there’s this really odd thing that, the only thing that counted for interaction was something that was done by the instructor. So, providing a lecture, providing a video, providing an assessment or providing an assignment, any of those sorts of things. Those are the only things that counted, so our interaction here… “Yeah, you said something and I’m the instructor that didn’t count what you said” That’s weird. So, now, there are parts of it (freshly hidden in the regular part of the definition) that if you go down there, that you’ll see that there’s the expectation that you respond to students and student requests. So, at least we’ve made that move that the student being part of the interaction is now a part of what counts, and that’s the great move forward.
Judie: And what is expected for substantive interaction, like how do you define the substantive part?
Russell: So going back again to the old one, that it was all just about content, that if you’re teaching a history course, as one might, that you’re talking about what happened in a particular battle, or what happened in 1792, or those sorts of things, particular things about the course, and interactions about basketball or other extraneous things didn’t count. But under the new rule, we’ve gone to an activity-based notion of it, and I’m going to read these, so stay with me on this, and they’re very short. So one, one of the activities is providing direct instruction. Two, is assessing or providing feedback on coursework. Three is providing information or responding to questions about the content or competencies. Four is facilitating a group discussion. Five is other instructional activities, as approved by the accreditor, that’s a really wide open one. But for these that, if you have any type of online course, I sure hope that you’re assessing what the students are doing, I sure hope that you’re responding to them when they ask questions, and so, you’ve already got two of those right there. The one that’s really in question is the one about direct instruction, and…everyplace else they talk about synchronous or asynchronous, but I know through some things that we learned about the Department of Ed’s thinking of that, and we asked this question directly of them during a webinar about direct instruction. At that time, they said that it was only synchronous education, and sometimes people freak out when I say that, and we are asking for clarification on that in writing, but remember that it’s two of the five, so even if they define it as just synchronous instruction, you’re probably meeting at least three of those five already if you have any type of quality course.
John: One of the issues, I think, that you’re also seeking to resolve is whether synchronous online office hours would count. Has there been any feedback on that yet?
Russell: Yeah, it seemed to us quite clear about the office hours, that that is something that would count and it’s something that did not count in the past. And so, it’s an interesting change for that and one of the reasons that they did that was one of the groups I was representing was competency-based education, and so, we’re going to get into notion of regular here in a moment, you know, how do you define regular for something that, by definition, is irregular in terms of competency based? And it’s based upon student pacing over the faculty pacing, and so, there’s a nod to that in terms of if you have regular office hours and have that posted on the syllabus or somewhere that that would count. And we’ve had some pushback from our financial aid friends, because that’s new to them. They said, “Well, that’s never counted before.” And so again, this is something where we’ve asked the question of the department and hope to get that in writing yet again so that that’s reaffirmed and everybody’s under the same understanding for that one.
Judie: You started to talk about regular, so how do you define “regular” interaction?
Russell: So regular? Yeah, as I was alluding to, that was the hardest one to do, because remember, we’re writing these for, depending on how you count, four to six thousand institutions. Some have short courses, some have competency-based, you think of every variation that you have out there. So saying “meeting once a week,” or doing something once a week just didn’t work because it didn’t fit all those different ones, and once a week would not be enough in a five- or six-week course, that’d be too little. So, we tried a formula and that was a disaster. So anyway, so we have these words, and then there’s a lot more, again, back to the relationship with the accreditor on this and what works. So, these are a little bit vague, but you need to work with your accreditor and how they’re defining these. So there’s really two parts to this. The first is going to be predictable and scheduled, and so this is something where either you have it in your syllabus, and then you have the syllabus at the start and here’s when things are going to happen, and then with that, that you may actually have a two- or three-week break where an instructor is not putting things out or you don’t have interactions, because it makes academic sense that you have the people out doing a paper or group work for two to three weeks and doing that. So that once a week would actually not work there, right? Or the predictable part of it was that maybe it’s not exactly in the syllabus, but what you do is you say, “Every Wednesday, we’re gonna meet or have office hours, or we’ll do something at webinar times.” So something predictable. So, that’s the first part of it. The second part of it was about monitoring the students’ academic engagement. And that was something we really brought in with competency-based education in mind, where what you’re doing is that you are actively following the student and making sure that they’re not out there on their own, and that you’re making sure that the student’s not floating and that you’re seeing that, “Okay, do they need interaction? Do they need some intervention?” Or the second part of that is what I alluded to before, or that the student says, “Okay, I need help with this,” or “I’m ready to move on to the next part of my competencies.” So that’s the other part of it is the bringing that together in terms of monitoring the engagement, so something that’s predictable, scheduled, and then also, outside of that, that you’re actually monitoring and interacting with the student.
John: Are there any requirements concerning the extent to which there should be interactions with individual students as compared to interactions with the class as a whole?
Russell: Well, both of them count. So if you’re giving a lecture, or if you’re doing a group discussion and doing that, that that’s a group thing, and so that counts. And also, remember, the second part of the regular was that you are responding to student requests, and so that’s on an individual basis. And when there is a federal financial aid review, or ”audit” as it’s called, of your institution, what they’ll do is they’ll go and take a sample of classes, and that they’ll look to see what happened in that course? Were there group interactions? Were there individual interactions? That they’ll look to see what happened and then they’ll look to see, does it meet the regulations? And have you developed faculty? Have you let them know that these are the expectations of them? That they’re looking for those sorts of things, and did it actually have an effect in the courses?
Judie: So what would be some examples of regular and substantive interaction that we could build into a course?
Russell: Yeah, that’s a really good question. You’re an instructional designer, you plan the whole course out, right? And you’re going to get more points on the regular side for the predictable and scheduled if you have a syllabus, that… it doesn’t have to be detailed down to every last thing that you’re going to do… but at least you’re showing that what are the expectations along the way? That, when are you going to have assessments? That, if you’re – let’s say that for some courses – that you’ll send out a video with a different lesson every Monday or every Friday, what you’re doing is that you’re hitting the marks on the regular, another is that you are showing that you have some expectations, in terms of the feedback and the feedback loop. And sometimes institutions have this as a policy, sometimes they leave it to the faculty member. But the more classes that you have where you show that the faculty person… you don’t have to respond immediately… but they’re showing that they will respond in 72 hours, not counting a weekend… that they will respond to the students. And there’s that expectation that they will do that because I had a question from one, that they had a faculty member that they put the discussion out there at the start of semester and then graded it at the end of the semester [LAUGHTER]. And first of all, that’s terrible teaching practice, let’s start with that, nevermind the regulations, but that faculty person thought it was good. And the other is, that there’s this expectation that, as you go along that you’re working with the students. So those are some examples of things that you’d want to do there.
Judie: So just a couple of different things that I like to try here is, I really like to try to encourage faculty to give feedback prior to the next due date. That just makes sense, so that if a student is making an error, they’re not going to repeat the same error because they haven’t gotten their feedback yet. So I just think, pedagogically, it makes sense to give the feedback as soon as possible. But I also like to just have faculty create a communication plan when they’re developing their course. I think faculty plan in their heads, you know, “I’m going to send this announcement, I’ll do this feedback, I’ll do X, Y, and Z.” But when they sit down and really map it out in a communication plan for their course, I think that really helps get into that regular schedule. And whether it’s date driven, or day-of-the-week driven or at specific points throughout the course when students reach different milestones, I think that really helps them. My understanding is that those types of things would help people meet the regular and substantive interaction definition. What do you think of that?
Russell: I love both of those ideas, and actually that, really, if you work with the instructional designers, look at what works in terms of good pedagogy, that these are the things that you’re talking about is that having a plan ahead of time and being open with the students so that they know, and then getting back to the students in between assessments so they have the feedback in terms of, they know where they might be falling behind a little bit in some areas and so that they know, “Oh, I don’t quite get that concept. And then, I have a math background and that was so key in mathematics that, if you don’t get this one, you’re not going to do any better on the next test right? And that’s probably true in so many different fields as well. And so, I love both of those ideas in terms of doing things and where you’re informing the student, and then keeping them engaged and then constantly moving them forward.
Judie: It’s great to hear that kind of feedback from you, thanks! [LAUGHTER] I hear a lot from faculty now, especially during COVID, when many are teaching in Zoom. And so they’ll record a live lecture with their students and, assuming that FERPA rules are followed, and there’s no students caught in the video or audio, they want to just show that recording again in the next semester, and want to know if they’re meeting regular and substantive interaction that way. And I tell them that, when they’re giving their lecture, that is regular and substantive interaction when they’re engaged with their live students. But I say that once you make a recording, and put it in the course, it becomes course content, because it’s no longer a unique experience with those individuals talking about their understanding of the course content. And I see like a real fine line there and I wonder what you think of that? Or how that might be interpreted? What do you think of using old recordings versus always expecting some sort of fresh and unique interaction with the students?
Russell: Yeah, I think if that’s all that you did, I think that you’d have a hard time in terms of meeting the regular and substantive interaction, and this is the one where we get back to the direct instruction question on that one, and we did gather that question plus several others and pose them to the Department of Education, because we felt that even since they released the rule that we were hearing different things from them than from the accreditors. And so I’m a little hesitant to give you a yes, that works or not, under the new rules or not until we get a better answer from the Department. My feeling was that, under the old rules that I felt a little bit better about that that probably was problematic. It might still be, but I’m kind of curious to see what they say about the synchronous versus asynchronous going forward. I think that, if that’s all that you relied on, I think that that’d be problematic that you would need to have other sorts of interactions that might make that work.
John: But videos that were custom created for that week’s activities, or that provide feedback for the class would count, right?
Russell: Yeah, the ones that are custom created.
Judie: I encourage them to make like small targeted videos for clarification. Like, to address a specific topic that they know that students struggle with, as opposed to just making an hour video of you standing at the front of the classroom, talking to people that future students don’t even know.
Russell: Yeah, and I think if you just use the video over and over again, and I certainly saw this in some engineering courses where they’re using the same ones that, what happens is that you have to update your materials every once in a while, too [LAUGHTER].
Judie: Oh, sure
Russell: You need to be doing that. And so I remember witnessing a course where they were falling behind on some facts or raised a lot of questions about advances that had happened after the video had happened, or were quite clearly dated, because they were talking about things that were going on in space as a future thing, instead of a past thing. And so I think, if nothing else, that you’re going beyond whether you meet these rules or not, that you’re diminishing confidence of students in terms of the value of what they’re receiving.
Judie: Sure, that’s a good point.
Russell: One other issue that we didn’t touch on so far had to do with the definition of an instructor, and that was a difficult one for us. And that was another one that Western Governors University got hit on this one. It was a finding against them. And that it seemed like some of the definitions meant like an instructor, that there was one person that was in front, and that a lot of institutions have gone to team teaching or bundled instruction, or using GAs or TAs or there’s several people in the course and with the unbundled instruction that WGU did that they had one content expert providing the content of the course and another one doing the assessment and maybe somebody else doing some of the advising. So you broke it up and that they weren’t counting that even though it was approved by their accrediting agency. So that is one where we have worked on “instructor” and we’re very clear in this, that it is what is approved by the accrediting agency that that is what counts. T hat was sort of alluded to before, now it’s very clear. And so if you have a non-traditional sort of model for your instructors or faculties, you may want to talk to your accrediting agency about how they view that and get something in writing about that.
John: I think that is a pretty common issue where there’s often a master course developed by the content expert and then again, there are instructional teams that work on the whole course, but the division there can vary quite a bit. And I know there’s a lot of interest in institutions in trying to scale online education to make it more efficient, and this is an area that certainly needs to be addressed with the accrediting agencies.
Russell: Definitely, definitely, yeah.
Judie: So these rules that we’ve been talking about also addressed student identity verification. So is the student identity verification related to the regular and substantive interaction? Or is this another area that requires a more precise definition?
Russell: This is actually a whole other area that was in a different part of the regulations, and this is one that actually went into effect in July of 2020, and it’s part of what the accrediting rules are, and there’s a whole list of things that the accrediting agencies are supposed to be looking for when they’re doing your accrediting reviews. One of the things that they’re supposed to be doing is making sure that the institution has, really, policies and processes to make sure that the student who enrolls in the course is the same one who’s completing and submitting the assignments in there. So it really is about academic cheating, and that this is only in the distance-ed world that they have to do this. I have to tell you, in a subcommittee, we tried to expand it and got beat back. So, sorry we lost that fight for you. But it’s still in distance ed where the accreditors are expected to check for that to make sure. And then the big change that happened in that is that, previously, there were some, what were considered ‘“examples” in there. And one was that you had some sort of ID, some sort of login ID for that or that you did proctoring, and that those were meant as examples. And those were taken out, because all too often, what would happen is that an institution would say, “Well, we have an ID!” and they would do nothing else. And so that was clearly insufficient in terms of doing it, and so, they’re raising the bar. The intent is that you have a plan, and that you’re executing the plan, and that you’ve worked that out with your accreditor, and that when that financial aid review happens, that you will be able to demonstrate what you’re doing and if it’s effective. Another part of it, there’s a second section to it, that also talks about that if you have additional costs, and so, let’s say that you’re using a proctoring software, and that that costs so much per student, that you have to notify the student at time of registration, that there’s an extra cost for that. And this is something that a lot of institutions have fallen short on, because what they’ll do is that they’ll notify the student in the syllabus, and so the first day that the student starts they see the syllabus, and all of a sudden they have to pay more money. And the idea is that the student should be able to have a choice at the time they’re picking between which course that they might take or know that they’re going to have an additional cost for participating in that course. And that rule is out there, and it’s a good one, because you’re being clearer to the consumer about what’s going on.
John: So authentication with a password to a course management system is not sufficient, and some type of proctoring software is, but there’s a lot of concerns raised with proctoring. Are there any other ways to authenticate students that meet the requirements without moving to software proctoring solutions?
Russell: Yeah, and I think that over the last year that we’ve seen, the concerns about proctoring software have risen to the fore, and there’s some good ones and that they do some good things, and so you should not throw them all out. But yet, you should pay attention to the concerns about that. But there are ways that we have worked on this in terms of different ways that faculty can work in terms of their assessments. One of the things we talked about is face-to-face proctoring, As distance ed grows, though, that gets to be harder and harder to find enough proctoring sites and the ability to do that, but that is an option. Some of the other things that have been proposed have to do with how you do assessments, and that having more frequent assessments and doing things where it’s easier to take the course than it is to cheat. That if you do like one or two big assessments per term, that it’s a lot easier to get someone to do those for you or the big papers and all that, so that’s one. There’s others where getting people involved in terms of group coursework, or other sorts of authentic assessment type of things, where you get involved in different sorts of things, where you have to stay engaged more and more often through the course, and it’s harder to get somebody else to do that for you. There are people who will take the whole course for you… that’s a problem. But the more barriers that you can put up, and we really do love our instructional designers, but the more that we can do to help faculty with thinking about assessment strategies and effective assessment strategies, the better off that will be with all of this. Aso there are other areas like… oh shoot, I’m blanking on… ICAI, they have a lot of strategies as well out there, and for some reason, it’s early in the morning here and I’m blanking on their name, but there’s an institute for academic integrity that has a lot of good resources on this issue.
Judie: Yeah, I think it’s great to encourage all faculty to work with their instructional designers on authentic assessment.
Russell: Yes, yes, yes! That success will be more sure if you work with your instructional designer.
Judie: So, do you think that this authentication concern is only for assessments? Or is it for day-to-day coursework and interactions, too?
Russell: Yeah, it’s really about any type of quiz or paper or anything that you’re going to be evaluating the student on. That’s really what it’s looking at, because there’s the opportunity for cheating or something bad to happen there. So there are other things that you do in terms of papers, you know, with Turnitin or other sorts of activities that people do or trying to create papers that are more authentic or real: “Write something about your hometown or work on a project in your hometown where there’s not a lot of papers.” [LAUGHTER] So, you can do those sorts of things where it’s harder to plagiarize.
John: It’s really nice to hear that open pedagogy projects, videos that students create, where they’re actively engaged in it, group projects, and all those things can serve the same role without moving to the extreme of proctoring.
John: It is good to note that any courses that require proctoring must list that up front so that students are aware of the cost. And the other issue with that is, as colleges enroll more first-gen students and more students from the lower income quintile, many students won’t have computers or networks that will necessarily support proctoring software. If students are working on their course through their smartphones, most proctoring solutions don’t work with smartphones. But it’s pretty easy for the student to take a video of themselves talking about something, so allowing faculty to have more options for authentication is something that allows for a more inclusive learning environment.
Russell: That was a huge lesson from the move to remote learning due to the pandemic, that you had so many students who did not plan to be in a remote course that uses online tools… that they were using, as you said, cell phones or different types of tablets that were not compatible with some of these proctoring software solutions, or that they didn’t have the adequate bandwidth for taking the test in that way with a full video… that that was a real problem, privacy issues with it. So there were all sorts of things that were problematic with that. And so, being upfront with the students is very good and we do often cite that there wasn’t a federal finding, but it was a student in Nevada, who was in a course and they were not notified that they were going to be using proctoring software. The student was pre-law, decided to flex his pre-law muscles, and got a whole bunch of students behind him and took it to the institution and ultimately went to the Board of Regents there, and all of those students had all of their fees repaid. It wasn’t a federal finding, but what was shown was that they were out of compliance with the federal rule, and the Board of Regents decided to remedy that.
Judie: So looking at regulations like this, we can see that online classes are held to a higher standard than face-to-face classes. Do you think similar requirements should also be implemented for face-to-face classes?
Russell: Well, I think what’s happening is that the vast majority of courses are now digital courses. And whether it is fully online, whether it’s hybrid, hyflex, blended, or just the old term that the OLC used to use of “web enhanced,” that you use the web a lot, even though that you meet face to face Monday-Wednesday-Friday, that we’re seeing all these digital tools going throughout. And what happened with the pandemic? It really took off, right? And so there’s even more of that is gonna happen. And some surveys that one of our organizations, Every Learner Everywhere did, that there was more interest and uptake from faculty in terms of, “Well, I’ve done this now I should do it again.” And so I think what’s happened is that we’re gonna see more and more use of digital technologies through, if not every course, the vast majority of courses. Well, the thing that happens is that these same sorts of problems are in all of these. And you and I know, keep this as our secret between us [LAUGHTER] but, all this stuff was happening even without technologies, right?
Russell: A lot of the cheating scandals in some of the service academies in the last few years had very little to do with technologies other than sharing some information. So we know that’s going on. So it’s gonna be interesting. This is one of the things that we’re looking at that I bet we’re going to see a lot of new guidance coming out of this Department of Education that recognizes that and may expand this out quite a bit more, because there are people in the department who have huge concerns about consumer protection issues and the use of online or digital learning regardless of where it’s used, and that they’re seeing that some of these rules need to be applied more broadly. So I wouldn’t be surprised to see that we get guidance that says exactly that coming out and that we have James Kvaal was just finally approved as the Undersecretary there. I think that that staff has been working on these sorts of things, and have been waiting for him to be approved. I would not be surprised that in the next three to six months that we don’t start seeing some new guidance coming out or answers to our questions. I don’t think they wanted to answer our questions until James Kvaal was in. And so I think that we’ll see clarifications and guidance about some of these things where we’ve had questions before, and how do they apply in a hyflex setting? How do they apply in a blended setting?
Judie: That’s good news.
John: And whether the rules are expanded or not, they’re just good practice… that regular and substantive interaction is good pedagogy.
RUSSEL: Yes! [LAUGHTER] Yeah, you really nailed it with that. And that was one of the things that surely the people that run the subcommittee and then the main committee were trying to look at: “What do we do that makes sense in terms of best serving the students?” And we have to remember at the end that these are consumer-protection practices that have to do that, there are also federal-financial-aid protections that aid is going to worthy activities, and so we need to remember that in all this.
John: We always end with the question: “What’s next?”
Russell: Well, I kind of previewed thata bit, that I really do believe that we’re likely to see several more clarifications coming out, or maybe some surprises coming out in the next few months. And so I think it would be good for people to pay attention to what’s going on, and we certainly write about whatever comes out in our WCET Frontiers blogs. So, be watching for that. And on something completely different, that we’re getting together some folks to work on the issue about veterans and their housing allowance. And just quickly on that, that veterans who take all their courses online, get about half or a little bit more of the housing allowance of veterans who take just one course face to face… they could have it all online, but just one course face to face. And it really is antiquated thinking, and it’s something that we need to get fixed. Because, I could be the same student in one term, take all my courses online, and the next term take just one course face to face. I have the same housing cost, I have the same family [LAUGHTER] I still need to eat, but somehow my aid is less. And so we’re working on that one.
John: And you shared many resources with us that we’ll include in the show notes, so those will be available on the website. Well, thank you for joining us, this was really helpful, and I think it’s going to benefit a lot of institutions and a lot of faculty and instructional designers as they plan for future semesters.
Russell: Well, it was a great pleasure being here with you today, and having a little bit of tea in the morning is always good. And so thank you, Judie, thank you, John for inviting me and for having me here.
Judie: Yes, thank you. This was fun. Take care.
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Rebecca: You can find show notes, transcripts and other materials on teaforteaching.com. Music by Michael Gary Brewer. Editing assistance provided by Anna Croyle.