The EvoLLLution | Building Clock-Hour Competency-Based Education Programs with Flexibility in Mind
While managing innovative programs in restrictive environments can cause significant issues for learners and colleges alike, a shared willingness to compromise and collaborate can smooth many of the rough edges.

In its simplest form, a clock-hour program is a set of non-credit courses that lead to the completion of a non-degree credential or certificate. Typically, such a program is offered in the field of career and technical education (CTE), resulting in licensure or attainment of qualifications for employment in the local economy.

Per definition from the U.S.  Department of Education, a clock hour is based on an actual hour of attendance, though each hour may include a 10-minute break and no less than 50 minutes of instructional activity. To be eligible for financial aid, a clock-hour program must consist of at least 600 hours of faculty-supervised instruction in the classroom, laboratory or shop, which may also include internship hours required for licensure or certification. However, an institution may also apply for eligibility for shorter programs provided those are for graduate or professional-level programs, though I will not address those options here. Lastly, full-time status requires a student to attend a minimum of 24 clock hours per week.

At Salt Lake Community College, through the School of Applied Technology (SAT), most of our clock-hour programs are offered in the Competency-Based Education (CBE) modality. These programs can be as short as 150 hours for Certified Nursing Assistant Licensure, or as long as 1,105 hours for a Welding Certificate of Completion. We have also been participating in one of the CBE experiments through the Department of Education Experimental Sites Initiative (ESI), allowing the college to provide financial aid in the form of Pell grants for CBE certificate programs that consist of 600 clock hours or more. That experiment allowed for a split disbursement model consisting of four or more payments as opposed to the standard requirement of two-payment periods for clock-hour programs.

 The Benefit of the Clock Hour Model

The way we have structured our CBE model at the SAT allows students to pay for only the amount of time needed to complete their program. It is essentially a subscription-based approach, sometimes referred to as the “all you can learn” model, whereby those who are motivated have the ability to significantly save on tuition costs. This is however only possible through the ESI, which allows the college to disburse aid in multiple payments—reducing the risk of overpayment—but with no penalties for finishing a course or program in a reduced amount of time.

In contrast, the standard (non-ESI) two-payment period required for clock-hour programs is very restrictive for CBE because students who complete it in less than the prescribed time—a key potential benefit and feature of CBE—would have to return funds to the Department of Education for those clock-hours not utilized. As we see it, it would amount to punishing those driven students who apply themselves and finish early.

Also, an advantage of clock-hour programs is the short-term nature of the training that often leads to a better paying job or a promotion. With several of our longer programs, students will typically invest less than half the time required for a two-year degree, and the earnings potential may be equivalent compared to that in a similar field of study.

A further advantage is that clock-hour programs are not term based and may be offered several times during an academic year with variable start dates—we allow students to start their programs weekly. It can also be designed with the student in mind and, especially for adult populations, afford more flexibility in when and where they are able to access their training needs. This last aspect is true for all-clock-hour programs and is not restricted to CBE.

Identifying and Addressing the Operational Challenges of Managing Clock-Hour Programs

There are multiple challenges because most, if not all, student information systems (SIS) available to colleges are designed to operate within the term. They do not work well for clock-hour programs and less so for competency-based programs. There are limitations on scheduling courses, billing for clock-hour courses, tracking attendance, assessing satisfactory academic progress (SAP), disbursing financial aid and recording grades and issue transcripts. I will summarize some of the workarounds that we had to create to make this all possible.

Because the SIS is typically designed for the credit hour, this has implications on how courses are scheduled as well as how tuition is assessed for those clock-hour courses. Our approach was assigning zero credit hours for each of our courses and listing the clock hours as contact hours. This allowed us to build the courses in the system and to designate a representative schedule. Then, by means of an external table that runs in a sub-system outside of the SIS, we determine the cost for a given course based on the approved clock-hour tuition rate, which is then sent back to the SIS through a process whenever a course registration occurs.

We also had to create a year-long term—July to June—with variable start dates. That allowed us to establish the effective tuition rate for that year and also define the catalog year for the course sections and curriculum in the system. It is not perfect, but it allows us to utilize the current SIS without the need to define multiple short part-of-terms and billing cycles.

To track attendance, we had to configure our external sub-system so that it reads the course registration from the SIS and then allows the creation of a schedule for the days and hours of the week that we expect students to participate in a given course or program. However, with CBE this is no longer a critical component because students are measured not by attendance, as in the traditional clock-hour system, but rather by how much work they complete in the form of activities and formative assessments as well as summative assessments that lead to competency attainment. Each of those activities is assigned an estimated number of hours required to complete the task, which then serve as milestones for measuring progress.

For financial aid, we opted for monitoring SAP and processing disbursements manually. The reason for this is because, prior to the implementation of CBE, the number of students applying for aid in the traditional clock-hour modality was very low, owing to the punitive conditions that I mentioned earlier. However, during the past two years the number of students accessing Pell grants has increased as a result of the ESI. This has added additional strain to the financial aid office, as these manual processes can be very time consuming for regular clock-hour programs and especially so for students in CBE programs in a non-term environment. Though there are now some products available for managing financial aid in a CBE environment, the high cost of implementation would be justifiable only if utilized as part of a comprehensive, college-wide solution.

Lastly, for grades and transcripts we devised the following scheme: MC (master competency: pass) and NM (not mastered: fail). Aside from those grades we have a W for withdrawal and TC  for transfer competency, when a course is waived based on prior coursework or documentation that certifies competency. We also created a separate section in the college’s official transcript specifically for students who were enrolled in CBE clock-hour courses, to display the grades attained in those programs.

The Potential Ramifications of Miscommunications in a Complex Environment

In a large institution such as SLCC that is providing both credit-hour and clock-hour programs, there is a high probability for unintentional miscommunications. There are too many differences between the two models and staff training is always one step behind when it comes to being prepared for all the different options that exist. With the high turnover in those front-line positions which typically are the lowest paid, the stage is set for students to be misinformed. The problem is exacerbated because of the large number of programs and options available, many offered in one campus but not another, and the amount of variability between those that have similar names—while their modality and type of outcome (i.e. degree vs. non-degree) may be very different.

Furthermore, with the rules and deadlines for financial aid so different compared to credit-hour programs, navigating the system can be complicated to say the least, for staff and students alike. For students receiving federal financial aid (Title IV funds), the greatest impact of the traditional clock-hour system is the possibility of having to return Title IV funds (R2T4) for completing the program sooner than anticipated. This happens when a student ceases attendance prior to the planned ending date. Under federal regulations, a student only earns Title IV aid equal to the amount of attendance, up to the total amount established for a payment period. Therefore, if those conditions aren’t carefully explained to a student who accelerates, there is a chance that he or she will be requested to return the excess aid previously disbursed by the institution.

While it has been possible to offer Pell Grants under the Department of Education ESI for CBE clock-hour programs, which amongst other benefits essentially eliminated the return of funds, this was only available to a handful of institutions that managed to participate in this limited experiment. Most colleges offering clock-hour programs have to follow the Department of Education’s previously established regulations for awarding financial aid.

Also, as of November 2019, the Department of Education has made a decision to end the ESI Competency-Based Education—Split Disbursement experiment. At this point, it is not clear what new disbursement process may replace it, if at all. Until that is determined, all affected institutions will have to comply with the existing requirements as previously defined for clock-hour programs.

How Colleges Can Work to Ease and Overcome These Obstacles

Upon enrollment, students are overloaded with information and despite multiple attempts to disseminate those guidelines there will always be a few who find themselves in situations that should have been averted. Therefore, orienting students and making policies and procedures available is not enough. I would suggest having systems in place to continually provide feedback on students’ progress status not only at the program level but also at the course level.

Short courses that are less than 50 hours may be more easily monitored because they are completed within two or three weeks. But when they are in the range of 50 to 100 hours or more, it is challenging to monitor progress in such a way that faculty and staff are able to prevent students from procrastinating and using up all their allotted time. That would end up being costly for students. For this, courses may be structured so there are modules with clear, measurable milestones that take no more than 20 hours to complete. That way, when a student misses completing one of those modules on any given week it provides an opportunity for faculty to intervene.

Likewise, at the program level, there needs to be a clear course sequence developed and displayed to the student, illustrating the academic expectations by means of a timeline and estimated course completion dates. This could be further augmented by displaying the student’s actual completion dates with clear markers for above or under performance, and the appropriate warnings when those events are likely to cause issues with financial aid. This program tracking tool should be updated at minimum weekly and it needs to be made available to all: students, faculty and staff. Being able to monitor weekly progress also creates an opportunity for faculty to meet with students one-on-one, to discuss any issues that may be preventing students from maintaining pace and to provide qualitative feedback. This may also assist faculty with the federal requirement of frequent meaningful contact.

Lastly, institutions should consider hiring coaches to work directly with students in CBE and clock-hour programs. Those individuals would be able to closely support students with their challenges by providing resources and reminders of the processes that are frequently forgotten, as well as serving as pacing monitors who can alert those at risk.

Next Steps: How Leaders Can Launch Alternative Program Models on their Campuses

I would research and contact other institutions that offer programs similar to the ones being considered. Learn from those who have successfully implemented those programs. Also learn from the mistakes that others have made. Some of the barriers may be very complex and difficult to overcome, yet there are likely some simple solutions if one is willing to compromise. Gather as much information as possible and plan accordingly. Nothing is worse than having to switch gears halfway through because of unforeseen issues.

Make sure that all stakeholders are on board and that there is institutional support coming from the very top. Some of the key stakeholders are Admissions/Advising, Office of the Registrar, Financial Aid and Office for Information Technology. All will be affected in some measure and everyone needs to contribute towards finding solutions. Of course, faculty will also need to be on board and it helps to identify those faculty champions who will slowly persuade the rest to adopt the new programs.

Technology is rapidly changing, and we have seen much progress in the past couple of years. While there are now some fairly mature solutions for CBE, sometimes it is best to develop the systems in-house because no one product can cater to the wide array of different models in existence. Costs will frequently determine what you are able to do, therefore keep an open mind.

We learned the hard way, and in some respects, we were building the vehicle while it was already moving. It doesn’t have to be that way.

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