June 1, 1999
Mr. Patrick J. Sherrill
U.S. Department of Education
400 Maryland Avenue, S.W.
Room 5624, ROB-3
Washington, D.C. 20202
Dear Mr. Sherrill:
The Advisory Committee on Student Financial Assistance is pleased to comment as required by section 491(d)(5) of the Higher Education Act (HEA), on the data collection requirements for the Distance Education Demonstration Program Annual Evaluation. We commend the Department of Education's (the Department) willingness to consult with the higher education community before finalizing the evaluation's data collection requirements. In that spirit, we believe there are several important policy issues that must be addressed in the program's design and data collection.
First, from the standpoint of Congress and the Advisory Committee, two principles are of paramount importance in fashioning an appropriate federal role and policy interest in distance education as it relates to Title IV student assistance:
- the maintenance and enhancement of access to postsecondary education for low- and middle-income students; and
- the preservation of program integrity.
That is, at a minimum, any changes in the federal rules governing student and institutional eligibility should do no harm to either access or integrity; and the burden of proof is on those proposing the change.
Second, given those two principles, the Advisory Committee is especially interested in: a careful assessment of the full range of distance education activities that are ongoing and feasible without any changes to the rules; a specific determination of the need for each proposed change and its likely effects; and a systematic evaluation of the costs and benefits of the change. In other words, the mere fact that an exemption from a rule is sought by a particular institution does not necessarily mean that the exemption is required by institutions in general or that it is in the best interests of higher education or the taxpayers.
On April 27, 1999, our Committee held a meeting at the University of Mississippi that included in-depth round table discussions on access and distance education. These discussions with leading distance education providers and other higher education leaders led to a consensus that there are many issues related to distance education that call for care and restraint in the development of federal policy. There is concern that distance education quality is unproven; there is potential for fraud and abuse if existing standards are relaxed; and there are significant implications for access in terms of cost and targeting of need-based aid. However, we have many more questions than answers, very bad data on distance education, and a sense that there is much more that needs to be known. These issues present thorny, difficult problems, and we urge the Department to proceed cautiously.
In light of this concern, the demonstration program evaluation is of critical importance, and must be more than merely descriptive of the type of program, technology and student participating in distance education. We recommend the data collection methodology be structured to support analysis among the following policy issues:
- The evaluation must demonstrate that access and program integrity are not compromised by the waivers granted, supported by comparable data across demonstration projects.
- The evaluation should address the characteristics of students that are most effectively served by distance education, and how to encourage students to attend programs that best meet their academic needs. For example, distance education appears to be primarily, but not exclusively focused on the adult education market, and some question whether distance education programs are appropriate for the 18-21 year-old undergraduate population.
- Many distance education programs are eligible to participate in the Title IV programs now. The evaluation should distinguish restrictions to aid eligibility--if any--by institution, program, student and mode of delivery. The evaluation should provide information on availability of Title IV aid and other resources, including institutional aid both from institutions granted waivers through the demonstration program and other institutions providing distance education without such waivers.
- The evaluation should include an analysis of the budgetary impact, both in terms of the institutions and students involved in the demonstration program and its eventual extension to distance education broadly, as well as the implications of its application to all institutions and students in higher education beyond the distance education context.
- Program integrity and quality are key issues, particularly for virtual universities. The evaluation should include an investigation of current state licensing, accreditation and institutional eligibility processes or other mechanisms that are being put in place to ensure consumer protection, quality and program integrity.
- The evaluation should address gatekeeping issues for institutions that may not meet criteria to participate in the program, but would have significant implications for program integrity--particularly to avoid correspondence school fraud and abuse scandals that have occurred in the past.
The scope of the distance education evaluation should be broader than the schools that request waivers if it is to effectively address the issues and concerns presented. Ideally, the evaluation should include a control group of distance education schools that are not participating in the demonstration program. At a minimum, the evaluation should include a component that looks at key issues across demonstration and non-demonstration programs.
In addition, the Department must provide assurances that it has the appropriate resources--personnel and systems--to adequately monitor administrative capability and financial responsibility of distance education institutions. The Committee also suggests that the Department should consider creating a liaison to strengthen its monitoring functions and assist institutions with providing data and other requirements.
As always, the Advisory Committee members and staff appreciate the opportunity to respond and hope that the Department gives serious consideration to the issues raised by the Committee and the higher education community. We look forward to continuing the dialogue with Department officials and would be happy to assist you in any way possible.
Sincerely, Robert C. Khayat Chairperson
cc: Advisory Committee members
The Honorable Richard W. Riley
The Honorable Marshall S. Smith
The Honorable David A. Longanecker
Ms. Maureen A. McLaughlin
Dr. Marianne C. Phelps
Committee on Education and the Workforce
Committee on Health, Education, Labor and Pensions