5 things you should know about online courses and federal Credit Hour regulations

Here is a question that is likely to come up in a variety of conversations about online learning: are the requirements of this course equivalent to what we expect in a face-to-face course? When administrators are at the table, the conversation will likely turn to federal regulations concerning the Credit Hour. Yes, there is actual federal regulatory language defining a credit hour for federal programs (34 CFR 600.2):

An amount of work represented in intended learning outcomes and verified by evidence of student achievement that is an institutionally established equivalency that reasonably approximates not less than:

1. One hour of classroom or direct faculty instruction and a minimum of two hours of out-of-class student work each week for approximately fifteen weeks for one semester or trimester hour of credit, or ten to twelve weeks for one quarter hour of credit, or the equivalent amount of work over a different amount of time; or
2. At least an equivalent amount of work as required in paragraph (1) of this definition for other academic activities as established by the institution, including laboratory work, internships, practica, studio work, and other academic work leading to the award of credit hours.

So, here are 5 things you should know about this area and complying with the regulations:

1. Your regional accreditation body will have its own statement of its expectations for how institutions within its jurisdiction should comply. The regulations charge accreditation bodies with enforcement. The regulations say Accreditors

• Must review the institution’s policies and procedures for determining the credit hours and the application of the institution’s policies and procedures to its programs and coursework;
• Must make a reasonable determination of whether the institution’s assignment of credit hours conforms to commonly accepted practice in higher education;
• May review and evaluate an institution’s policies and procedures for determining credit hour assignments through use of sampling or other methods in the evaluation;…

2. In my experience, faculty (who are accustomed to a fair amount of autonomy regarding their courses and course design) will want to debate the fundamental merits of the Credit Hour. Such a debate is, for all practical purposes, a moot point. Compliance is required in order to receive Title IV funding and other federal financial assistance. But here is something interesting: faculty will assume that classroom-delivered courses are the baseline. Government documents, however, explicitly state that the definition of a credit hour neither requires nor implies any minimum amount of seat time (even for classroom-delivered courses). In other words, the standards don’t privilege any type of course over another. There is no implied instructional gold standard.

3. The regulations specify a minimum standard. An institution can exceed the minimum expectations for the definition of an institutional credit hour. This is where it is unclear if institutions can impose greater expectations upon one type of course over another. In my opinion, in the long run, it is better for institutions to develop standards that are agnostic in terms of delivery modality. If the faculty are concerned that online learning is “less than” placed-based learning, attempt to broaden the discussion so that reasonable people would agree to apply them to any course.

4. If your institution wants to use paragraph 1 as the main criterion for assessment, notice that the regulations don’t dictate particular amounts of classroom time (i.e. seat time) versus out-of-class student work (i.e., homework). Instead, the emphasis is the amount of time the student spends “academically engaged” (the government’s phrase). For classroom-delivered courses, the regulations allow us to give the benefit of the doubt to classroom time as academically engaging (although that can be debatable), accounting for 1/3 of the roughly 45 hours of student engaged activity expected for a credit. But this is only a convention! For any course (but particularly relevant to online-delivered courses), the breakdown for course design doesn’t need to follow the conventional ratio of 1/3 instruction to 2/3 homework. Engaged time doesn’t need to be spread evenly throughout the term, either.

5. My guess is that there are only certain types of institutions that will rely on paragraph 2 for compliance. Defining “student achievement” is not just a can of worms…it can be a fully loaded bear trap or swarming bee hive. Most faculty never get the opportunity to work with an instructional designer, which means most never have a discussion about how to craft effective learning objectives. Which is too bad, for a lot of reasons. But one of those reasons, is that it makes it unlikely that faculty will learn how to talk professionally and nondefensively about how their course results in student learning. Which means they be less likely to tackle the larger and more interesting issue of the relationship that we expect between instruction and student learning. As one of the documents states “at its most basic, a credit hour is a proxy measure of the quantity of student learning.” When an institution increases its use of online learning, an opportunity arises to encourage conversation, reflection, and improvement of the educational experience.

References and further reading:

DCL ID: GEN-11-06 Subject: Guidance to Institutions and Accrediting Agencies Regarding a Credit Hour as Defined in the Final Regulations Published on October 29, 2010. https://ifap.ed.gov/dpcletters/GEN1106.html

DOE. Program Integrity Questions and Answers – Credit Hour http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/credit.html

SACS-COC Credit Hours Policy Statement. http://www.sacscoc.org/pdf/081705/Credit%20Hours.pdf

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