Can You Measure Regular and Substantive Interaction between Students and Faculty?

August 22, 2018

For those in higher education administration, there are numerous government regulations that require measurements that at times are hard to define and often harder to prove. From the federal level, sometimes these come from the Secretary of Education, but mostly they come when the federal government updates the Higher Education Act, the law that governs much of the industry.

Recently the Secretary of Education proposed a halt to one of these regulatory initiatives, the very controversial one called “Gainful Employment.” Gainful Employment came from a previous Higher Education Act reauthorization and was intended to push the for-profit education industry to be accountable for the career opportunities they promise. Unfortunately, the definition of Gainful Employment correlating your academic major with job titles was hard prove. For the not-for profit institutions, it was even harder to tie Liberal Arts degrees to career paths.

The latest reauthorization is due to expire. The reauthorization now sits in the US Senate which is in the midst of a flurry of activity around the Supreme Court nominee and other politics.  This means it is likely to be extended and go to an expedited rulemaking process. There is no way to predict how things will go, but there is ongoing concern over student debt and the effectiveness of online education. For industry insiders, the big question is “What is the next Gainful Employment?” What is the new regulatory buzzword? Will “reform” come in the form of a new term or will a somewhat obscure one rise to the top.

Recently I was in a meeting with a client and they were seeking some data on how their faculty member interaction with students can me measured.  They were seeking data to demonstrate Regular and Substantive Interaction which turns out is a fairly undefined Department of Education term whose origins come from a desire to differentiate correspondence programs from fully online degree programs. It comes from a directive from the Secretary of Education that “All Title IV eligible programs, except correspondence programs, must be designed to ensure that there is regular and substantive interaction between students and instructors.” Inside Higher Ed recently published a summary of Regular and Substantive Interaction

Our client’s LMS system tallied faculty activity in the form of delivering lectures, assigning work and publishing. The system also tallied the time students were online but neither tallied the direct interaction between the two. By using our CorrectEnglish product and tracking comments on papers and assignments, McCann can tally the desired substantive interactions. With the addition of an automated, daily report, we were able to help our client meet their federal requirements. Now online programs can measure “Regular and Substantive Interaction” and do so at just a few dollars per student per semester while providing them the powerful browser-based writing tool called CorrectEnglish.

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