Neg Reg Panel Discusses Clock-to-Credit Hour Conversion, State Authorization Issues

By Brittany Hackett, Communications Staff 

Negotiators convened Wednesday in Washington, D.C., for the first portion of a three-day session titled “Program Integrity and Improvement,” where they discussed the clock-to-credit hour conversion regulations and state authorization of distance education programs and foreign locations of domestic institutions. 

According to Carney McCullough, director of the policy implementation group for the Department of Education’s (ED) Office of Postsecondary Education (OPE), the focus of the clock-to-credit hour regulation is to ensure that when institutions that have traditionally measured academic instruction and progress in clock hours convert those measurements to credit hours, there is not an increase in the amount of Title IV aid for which students qualify. 

“The main goal is to continue to be sure that students receive the same amount of aid for the same amount of coursework” and to maintain a “level playing field among students,” McCullough said. 

Critics of the current rule have said the formula is confusing and difficult to comply with because of the number of exceptions for certain circumstances, a sentiment that was echoed by members of the rulemaking panel.

“I understand the basics of why we have this, but it’s hard to administer and difficult to explain to students,” said Brad Hardison, financial aid director of Santa Barbara City College.

While there was some discussion of how to simplify and clarify the clock-to-credit hour conversion, many members of the panel said they need more information on the issue before they can weigh in. Representatives from ED said they would bring experts to discuss the issue and proposed language to the next session, which is scheduled for March.

The panel also discussed regulations for state authorization of distance education and correspondence education providers so that they can be considered legally authorized to offer a postsecondary program in a particular state, as well as participate in Title IV aid and other federal programs.

Previous regulations on the issue specified that institutions offering distance education programs in states other than the state where the institution is physically located, would be required to meet any state requirements to be legally offering distance education in that state.. However, the U.S. District Court for the District of Columbia in 2011 vacated the regulation on procedural grounds, followed by a 2012 appeals court ruling that the regulation was not a logical outgrowth of ED’s proposed rules. 

Many negotiators said yesterday that they would like to see the process for receiving state authorization for distance education programs simplified, noting that the complexity can often hinder students’ efforts to complete the programs or even enroll in them.

According to Melissa Gregory, chief of enrollment services and a financial aid administrator at Montgomery College in Maryland, many institutions have had to deny admission to students from particular states if they are unable to get the necessary authorization.

“It’s very confusing to explain to students why the education they receive as a resident in another state is different from the education they will receive in my state,” Gregory said.

The final issue discussed in Wednesday’s meeting was state authorization of foreign locations of domestic institutions, which hasn’t been specifically addressed in state authorization requirements. While this potential gap in the regulations is of concern to ED, non-federal negotiators cautioned against additional regulation in the absence of a reported problem.

The negotiators will meet Thursday and Friday to discuss transparency and fees surrounding the use of debit cards for federal financial aid credit balances, repeated coursework, and the definition of adverse credit history for PLUS loans. Stayed tuned to Today’s News for continued coverage of the negotiations.


Publication Date: 2/20/2014

Sally L | 2/25/2014 4:36:11 PM

The fact that non-degree granting schools are required to measure progress in clock-hour units is another frame from which to view this conumdrum. In origin, I believe the exclusion of "non-seat" when measuring course work completed was formulated during a time when many students attended trade or vocational schools in which a student's education was entirely hand ons. I imagined this made sense in the past, but with the advent of internet and the computer an education program often includes non-seat time. And, in the context of arts conservatories, course work done outside the class is crtical to academic progress of the student. For example, musicians, actors and dancer all must do preparatory coursework outside the classroom in order to benefit from the "seat-time" instruction. Imagine learning to play an instrument without practicing with that instrument on your own. Imagine learning to perform a role as an actor if you did not memorize a script or practice performing it on your own. Imagine performing a dance if you did not rehearse the part on your own or gave yourself no time in your schedule to recouperate or prepare for class. Imagine as a dance student, dancing thirty hours per week. It's time recognize that clock-hour measurements are incongruent to the realty of the design of most programs at the present time.

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