Thursday, August 13, 2015


Accelerator, Brake, Accelerator, Brake

The “policy wonk” level on this post is turned up to 11.  You’ve been warned.

If you haven’t seen Amy Laitinen’s excellent piece on the Education department’s failure to engage with its own sanctioned experiments with competency-based education, check it out.  (Admittedly, that may be the least catchy opening line ever.)  Laitinen points out that when the DOE opened the door a couple of years ago for colleges and universities to offer degrees based on demonstrated competencies, rather than seat time, a fair number of colleges went for it.  But almost none have actually started, because the DOE is taking its sweet time in issuing guidance for how it wants CBE done.

In other words, as an industry, we’re flooring the accelerator and the brake at the same time.

“Guidance” matters in a host of ways.  Many of the financial reporting rules to which colleges are subject are based on seat time and credit hours.  (For example, FTE’s --the typical measure of enrollments -- are based on credit hours.  How you would determine FTE’s in a CBE program isn’t obvious.  “Satisfactory Academic Progress” for financial aid eligibility is based on credits attempted.  Without credits, how do you measure that?  Prior learning assessment isn’t eligible for financial aid; at what point does PLA stop and CBE start? In the context of CBE, what’s a “full time” student?  I could go on…)  These may sound picky, and in a way, they are.  But if a college isn’t in compliance with the relevant regulations, the financial and legal consequences can be severe.  (If you want to watch a CFO’s eyes get really big, sneak up on her and suddenly yell “audit findings!”)  So colleges, quite sensibly, are looking for guidance from the DOE on all of those second-level issues.  And the DOE isn’t stepping up.

Which raises the obvious question: why not?  

I can think of a few possibilities, but I have to stipulate that none of these is based on any inside knowledge.  Anyone with inside knowledge -- Paul LeBlanc, I’m looking at yooouuu…- is invited to shed light.

In the best of all reasonably possible worlds, it’s just the first one, and they’re poised to strike.  

In the meantime, though, I’d love to see some thoughtful discussions of questions like the definition of FTE’s or SAP in the context of a competency-based program.  I see great potential in hybrid programs, and in breaking down the barriers between prior learning assessment and CBE, but the Feds need to step up.  Done right, the breakthroughs in these areas for which CBE is the catalyst could benefit all sorts of programs.

In the meantime, we rev the engine at a full stop.  Thanks to Amy Laitinen for connecting the dots.

Another possibility: turnover within the upper levels of DOE. I've had several projects with the feds lose momentum then die when a person high in that agency's food chain leaves and that person's replacement has different priorities. (There are occasional cases of "I'm in charge now, and that's not my idea, so kill it," but in my experience that's rare.)

This may not be the case -- your other possibilities also make sense, including the interference of the Trilateral Commission and the Lizard People -- but it's another possibility.

A less likely possibility is that external pressure came from elsewhere and killed or wounded the project. You would not believe the number of potential stressors on any mid-sized government project. Anything from lobbyists to senators who got an idea from an in-flight magazine to personal turf battles within the agency can gunk up the works. Considering that this plan would be a significant change in the way business is done, I could see that as a possibility. Not likely, but possible.

These aren't problems particular to the feds, of course. These are risks within any organization of great size. General Motors was notorious for this kind of malarkey.
If the problem lies in the rule-making process, then it is possible Department folks at the top of the food chain had one vision, but the rank-and-file bureaucrats who have to actually make the rules have another, and are moving extra slow in the hope (or expectation) that changes at the top will eliminate the need for new rules. I have seen this before, particularly in the case of demands from DOE that they admit were just passed through from OMB, and constitute a ridiculous burden that will never produce results (positive or negative). So this could be an example of "weapons of the weak" in operation.
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