Is that online student who they say they are? Expectations for verification of student identity

Let’s imagine Bill applies to attend your college or university. Here are some expectations that we could assume honest and reasonable people can agree on:

  1. Bill should actually exist and not be a fictional character.
  2. The person who shows up for courses saying he is Bill should actually be Bill, and not Tom.
  3. Completed assignments that Bill submits represent his actual work and not work completed by, say, Mary.

The typical instructor for the typical on-campus course pays the most attention to #3.  We check for plagiarism, we institute Honor Codes and Policies Against Academic Dishonesty, and we have students sit every other desk during exams. A much fewer number of instructors take steps to ensure #2.  They might check student ID cards before exams, much like the guard at airport security trained to match your face to whatever mug shot ended up on your drivers license. And I wager most of us have never even met an instructor who has had #1 cross their mind (although I did once have a student who I found out later was in a witness protection program and so he was, in a sense, fictitious).

But what if we switch it up and just talk about the online course? It suddenly becomes clear just how much we have relied on the personal relationships that come from same-time, same-place instruction. Can we really assume that Bill exists? that we haven’t been working in actuality with Tom? that Bill’s excellence in equations isn’t really Mary’s? Online courses don’t make people lose their scruples, but it is an environment where the fraudulent and the cheats have an easier time because instructors no longer have the additional protections of face-to-face contact.

The government recognizes this too. Part H of the The Higher Education Opportunity Act (2008) requires accreditation bodies to require that

an institution that offers distance education or correspondence education to have processes through which the institution establishes that the student who registers in a distance education or correspondence education course or program is the same student who participates in and completes the program and receives the academic credit.

The accreditation processes themselves spell out the requirements. For example, here is language for the most relevant point from the SACS-COC document Distance and Correspondence Education Policy Statement

At the time of review by the Commission, the institution demonstrates that the student who registers in a distance or correspondence education course or program is the same student who participates in and completes the course or program and receives the credit by verifying the identity of a student who participates in class or coursework by using, at the option of the institution, methods such as (1) a secure login and pass code, (2) proctored examinations, and (3) new or other technologies and practices that are effective in verifying student identification. [emphasis mine]

So, given that this requirement has existed for several years, you’d imagine that there would be some standard solutions, right? Yes and no.  Solutions? no. There are no foolproof solutions, especially for #2 and #3. Recent changes to government processes, such as for the FAFSA, have made #1 much more difficult. And most institutions have processes in place that can be modified to work for the online students–like requiring a social security card or a passport or a video interview. Of the dozens of institutions I researched for this essay, none expect course instructors themselves to verify that Bill exists.

So, Bill is admitted as a student.  What happens next is the single most universally recognized best practice:  A secure login and passcode managed through an “Identity Management System”, (commonly known as an IDM) along with an “Acceptable Use Policy” that tells students not to share their information. The government allows institutions to trust their students to not give out their login and pass code to others. Sanctions for violations are spelled out in an Acceptable Use Policy, as the institution sees fit. In best practice, rules and processes are documented, applied systematically for all students, and protect student privacy.  So, the instructor who uses the tools provided by the University (such as the learning management or the institutional email account) isn’t expected to worry about expectation #2.

Which leaves expectation #3.  Ensuring that Bill-the-online-student submits his own work is left to the instructor, just the same as it is for Bill-the-on-campus-student.  This is an area in which the government has not indicated minimum requirements or even standards by which to measure compliance. And nothing so far indicates that accreditation bodies expect institutions to make cheating impossible. But we aren’t supposed to turn a a blind eye to either.

So, even if the government doesn’t require proof, what are reasonable expectations we should have when evaluating online courses in terms of how they ensure academic integrity?

The short answer is: it’s much less about the technology and much more about the teaching. Here is where the eLearning community has developed some instructional best practices.  Several are aimed at reducing a student’s temptation to cheat. For example,

  • Make academic integrity part  of the culture.  Communicate to students regularly about it and in many forms, such as in orientation materials, on syllabi, and within assignments.
  • Create assignments that make plagiarism difficult.  For example, requiring several drafts of a paper instead of one final paper makes it more difficult for a student to use online paper mills.
  • Assign multimedia projects that show the person behind the name with a student’s voice or image.
  • Use “authentic assessment” activities and assignments that require active student engagement, such as journal, group projects, portfolios, and debates.

If a traditional “pencil and paper” type exam is needed, explore if your learning management system (LMS) offers options for randomizing exam questions. Set a limited window for exam completion.  Use software or an online tool that simulates a proctored environment.  Or, if necessary, require the students to find a qualified approved proctor in their locale.

An institution can offer these suggestions to instructors through workshops, training, instructional design assistance and other resources that support online course design and development. IT can help by testing tools and applications and recommending solutions that are both effective and reliable. And eLearning staff can help instructors to imagine different pedagogical strategies that are most likely to engage students and improve their learning experience.

Learn More

  1. Consortium of College Testing Centers
  2. Higher Learning Commission, 2012, “Practices for Verification of Student Identity
  3. Johnson, Lisa Marie. 2012. “Proactive strategies to promote academic integrity.”
  4. Middle States Commission on Higher Education, 2015. “Verification of Compliance with Accreditation-Relevant Federal Regulations
  5. US Department of Education, 2011. GEN-11-17. “Fraud in Postsecondary Distance Education Programs – URGENT CALL TO ACTION”
  6. WCET, 2008, “Are Your Online Students Really the Ones Registered for the Course? Student Authentication Requirements for Distance Education Providers”

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