The EvoLLLution | Will the OIG Audit of WGU Cool Interest in CBE?
Though a number of changes are clearly needed to create a system of regulation that protects students while also inspiring innovation, the Office of the Inspector General’s report on Western Governors University provides other institutions delivering CBE programming with an understanding of what to avoid in the short term.

The Office of the Inspector General’s audit of Western Governors University’s course-based Competency-Based Education (CBE) model was a hyper-literal interpretation of federal regulations. What effect will the OIG’s conclusions, recommending the return of more than $700 million to the U.S. Department of Education, have on the CBE movement? Will it cool interest in experimenting with, investing in, and scaling CBE programs?

First, it’s important to note that few people in the field expect that the U.S. DOE will actually require that Western Governors return over $700 million in Title IV funds. Even so, many institutions have examined the findings with interest in order to determine how to proactively adopt a “hyper-literal” interpretation themselves, or at least be able to justify their programs should the OIG come knocking.

There are three primary places wherein impact from the OIG may be felt:

  1. Western Governors University themselves
  2. Colleges and universities with active CBE programs (or those deep in development)
  3. Every other college and university

There are also many other audiences affected, including policy makers, industry advocates and educational reformers, however these primary three are the most direct, and those addressed here.

Impact to WGU and Prospective Students

First, WGU initially had to respond to the OIG’s report, and doubtless has had a lot of calls from various media outlets. There may be some minimal impact in some prospective students’ minds if they read a headline in passing that mentions something about the OIG (which sounds very official) and a request to return $721 million (which sounds very dodgy.) A prospective student might be made more cautious in considering WGU because of this, but only because of lack of understanding. That said, in traditional media sources, this has not had a lasting news cycle that a typical post-traditional student would be following with interest, unless they are in the field of higher education itself as a profession. The impact should be minimal from a student enrollment perspective. Primarily I would speculate that it has taken a great deal of internal time on behalf of the institution, time they could have spent in other efforts, which to educators is sometimes painful on principle.

Impact to Colleges and Universities with CBE Programs

Many of us at institutions with active and growing CBE programs read the OIG report with interest. Top of mind was “What do we need to do to avoid this type of situation?” Again, while the industry of higher ed is firmly behind WGU, it’s not fun for anyone to have time and attention sucked away from the primary purpose of an institution of higher learning. Indeed, Part 2 of WCET’s initial coverage of the issue addressed this concern—How much should we panic? The answer is not at all. What we should do is be attentive to the OIGs interpretation so we can avoid the same circumstances in our own programs—whether or not we agree with their interpretation. (Most of us do not, by the way.)

Think of it as a playbook in “how to avoid the OIG’s unfortunately literal watchdoggedness.” In this way, it’s instructive to other programs in CBE who can now make adjustments, or rather clarify their communications of those adjustments, in order to avoid similar circumstances.

We, as CBE advocates, owe a debt to WGU for taking one for the team. This report has been more instructive than all Dear Colleague letters to date in order to concretely provide instruction around the interpretation of Regular and Substantive Interaction.

Having said that, the institutions that are out in front, leading and scaling CBE programs, are not doing it because it’s yet another thing in higher education. These institutions are doing it because they believe it meets the needs of learners, they believe that it’s effective, they believe that it can be scalable, sustainable, low-cost, and flexible. They believe that this is an imperative of higher education – providing lower-cost, high-quality programs built around the specific needs of contemporary learners. We will not be dissuaded by the OIG’s report.

We are the believers.

Impact to Every Other College and University

The primary impact of this ruling will be at colleges and universities that do not currently have CBE programs: institutions who were either thinking about initiating CBE programs, or who already did not believe it was a good fit for them. For those institutions who weren’t planning on getting into the CBE game, this is just more reason not to.

For those institutions who were thinking about potentially exploring CBE programs, however, this might have a dampening effect.

This is not necessarily a bad thing. CBE programs are expensive to design, develop and deliver. In many cases, the technology systems are not yet there to adequately scale them, even if the curriculum is. Sitting out the first, second, or fifteenth round of development of CBE programs might not be a bad thing. Being on the bleeding edge, or even the cutting edge, is exhilarating but expensive, full of fits and starts with as many setbacks as victories. Waiting to discover more evidence of what works, and for what type of student, can be a good strategic choice for many institutions.

What Can the Government Do to Support Innovation

Innovation is happening despite governmental regulations, and also, in many cases, despite governmental support. The challenges of participating in an official experiment are many. It is time-consuming, resource-intensive, and takes valuable time and energy away from the fun stuff—actually fixing the problem.

The best thing the government could do to support innovation is to provide clear definitions and interpretations. Higher education institutions can then innovate and push the boundaries of those definitions. Pick a guardrail—almost any guardrail—and we will innovate within it.

Think of Western Governors University. Created out of a fundamental need, grown on a unique model, WGU innovated within the traditional credit-hour framework. Then, subsequent legislation in the reup of the HEA in 2005 created the Direct Assessment provision to help WGU, which WGU declined. Now, over 10 years later, they are getting their knuckles rapped publicly, and that censure has nothing to do with course-based versus direct-assessment CBE.

Unfortunately, the analysis by the OIG did not reference the student experience or outcomes. The OIG’s own report mentions that “we did not assess whether the school’s model was improving educational quality or expanding access to higher education.”

This is particularly important as a reauthorization of the Higher Education Act is considered in the House and Senate. In the field there are significant concerns about PROSPER, the House’s reinvention of the act, which would dramatically reduce regulations designed to protect students. The Senate committee asked for public feedback in advance of next steps in crafting a version. Of particular importance are the definitions: What is distance education versus correspondence courses versus CBE? What is Regular and Substantive Interaction? How “regular” is “regular”? What innovative models should attempted to be defined and articulated, and if they are, how do you leave room for future innovation?

The most critical opportunity to support innovation is to begin by evaluating programs based on learner outcomes. If federal and state governments, as well as accrediting agencies, could focus on quality outcomes for students, that would help innovation. Legitimate higher education institutions will be able to demonstrate through learner outcomes the efficacy of their educational models. Ultimately, this report by the OIG will only serve to galvanize support for innovation and change.

And we should, each of us, send a $10 cheque to WGU. Because of their leadership, we now have some measure of clarity with which to move forward.

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