Federal Financial Aid and CBE

Hello All!  If you didn’t know, I had a brief break from blogging about my dissertation (I’m sure the entire internet noticed;)

I have joined the team at Southern New Hampshire University as their Assistant VP for Academic Technology and Course Production.  SNHU is an amazing organization focused on quality and innovation in online education, and I am thrilled to be working with an amazing team there.  (I’m using “amazing” quite a bit with regards to SNHU, however I am not planning on toning that down.)  I will definitely miss Tri-C and all the dedicated colleagues I had the good fortune to work with over the years; we did good work together for the students of Cuyahoga County #MissionDriven!

So I needed to buy a house and sell a house and all those many involved things that take up a lot of time, and are (generally speaking) fairly stressful.  We’re embracing them with an air of adventure and confidence that there is an end-point to this transition.  For the time being I’m calling a great Airbnb place as my home, and have set up my Surface Pro on the dining room table where I’m diving back into it.

Once more unto the breach, dear friends, once more.

I’ve found most of my cultural references are Shakespearean.  I’m definitely the life of the party, that’s for sure!

In any case, check out this latest section on my (revised) understanding of the U.S. DOE’s distinction between “Direct Assessment” and what we’re commonly calling “Credit Conversion” (I’ve also seen “Credit-Based CBE,” so any norming on that language would be helpful.)

All comments and feedback welcome!  There may be elements I haven’t captured, so any help in making it better is greatly appreciated:)  Big shout out to Kathe Kacheroski, who also joined the SNHU team as the Associate VP for CBE/SNHU Accel for her counsel on this – though any errors are decidedly my own.

Federal Financial Aid for CBE Programs

            Federal financial aid has historically only been available to students at institutions who use traditional Carnegie credits.  As noted in the Dear Colleague letter, GEN-13-10, from 2013, the majority of CBE programs currently operating are “offered in credit or clock hours and can be accommodated under the current title IV, student financial aid regulations as non-term programs” (para. 2).  Programs that fall into this “credit conversion” category, whereby Carnegie credits are used to track progress towards degree, but where students gain those credits in a competency-based, often time-variable manner, do not need to do anything additional to make their programs eligible for financial aid.  An example of this type of program is that offered by Western Governors University, which had been operating under this “credit conversion” model since its inception in the latter 1990s.

In 2005, Section 8020 of the Higher Education Reconciliation Act (Pub. L. 109-171) for the first time enabled direct assessment CBE programs to be eligible for title IV funding.  This type of program is indicated by students progressing upon completion of assessments, and progress being tracked solely by those competencies “in lieu of measuring student learning in credit hours or clock hours ” (Dear Colleague Letter, GEN-13-10, 2013, para. 3).   For programs that wish to be considered as Direct Assessment programs, in order to receive federal financial aid (title IV funding,) they must utilize a provision made available in the 2005 HERA, and apply to be approved as an experimental site for CBe.

Experimental Sites

The federal government recently expanded federal financial aid eligibility to institutions that use solely CBE as a select number of experimental sites.  These focus of four specific types of experimentation:  (1) entirely CBE programs, (2) hybrid programs with a blend of CBE and traditional credits, (3) PLA- programs, and (4) work study for near-peer counseling (Competency-Based Education Network, 2014).

In a Dear Colleague letter from 2013, the U.S. Department of Education invited colleges and universities to apply to participate as an experimental site status in order to receive federal funds for programs that utilized CBE instead of credit hours.  In order to apply for this status, however, colleges must, in their application for experimental site status, provide an equivalency for how many credits the competencies represent and how it determined the equivalencies.  The Department then uses these to determine eligibility and award funding.

Before the Department will approve such a program, though, certain other criteria must also be met, including approval of the program by the institution’s accreditor, which must also have reviewed and approved the equivalencies.  Certain types of learning are expressly not eligible for funding through this experiment, including PLA, programs at foreign schools, any coursework prior to the program admittance that would be considered prerequisite, programs related to teaching credentials at the K-12 level, and remedial coursework (Dear Colleague Letter, GEN-13-10, 2013).

As applications followed, Southern New Hampshire University’s College for America program became the first to be formally approved as an experimental site for direct assessment; additional colleges were interested at the time including Capella University, Northern Arizona University and Brandman University (Fain, 2013).  Each of these schools was on the preliminary list of participants for experimental site status as of April 2015 (Preliminary List of Participants, 2015).

For the subsequent 2 years, however, there were few developments from the U.S. Department of Education (Laitinen, 2015).  Though colleges have asked for guidance from the department on how to proceed, and the department had committed to having guidance out by the beginning of June, 2015 (Laitinen, 2015).  Finally, the Competency-Based Education Experiment Guide was published by the U.S. Dep artment of Education in September of 2015 in order to give colleges specific requirements, policies and procedures in order to implement their programs.

Figure X:  Title IV Federal Financial Aid CBE Decision Tree

Federal Financial Aid Decision Tree.PNG

The decision for an institution to proceed either with “credit conversion” or full direct assessment is one that requires analysis, as the requirements for experimental site status enable the institution to gain flexibility around dispursement and direct/indirect cost, but still require the institution to design the program with credit equivalencies.  Those credit equivalencies are used to justify the robust nature of the program to both the accreditor and the U.S. Department of Education  (Dear Colleague Letter, GEN-13-10, 2013).

Another experiment that may have implications for CBE is the Education Quality through Innovative Partnerships (EQUIP) experiment whereby higher education institutions are invited to submit for approval to be Experimental Sites for partnerships with non-higher education institutions to provide content and learning through third-party providers (U.S. Department of Education, 2015) .  Currently, programs are not eligible for federal financial aid if more than 50% of the degree program is delivered by a third-party provider.  These Experimental Sites will not be subject to that restriction, and it will enable experiments with alternate educational providers that are emerging, particularly in IT fields.  The pilot program would utilize third-party quality assurance entities to ensure the quality of these programs, and is thought to support access to boot camps, MOOCs, and other short-term certificates (Field, 2015).

Thanks for reading!  I’ll post an expanded citation list in the next few weeks.  The literature review feels like one of those old-fashioned sponge toys I’d get as a kid in my Christmas stocking or for my birthday.  Do you know those?  They’re super-small, almost like pills, but they are really these super expanding sponges, and they make a giant sponge character when you soak them in water.  They just keep growing.  That’s where the lit review is at right now.  But I’m going to cut that down to size – we need to get this show on the road!





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