Defining Competency

The U.S. Department of Education and regional accreditors are closer to being on the same page about competency-based education.

Earlier this month the Council of Regional Accrediting Commissions, which represents the seven regional accreditors, issued a common framework for how to assess and approve competency-based programs. The Education Department followed last week, with a letter to accreditors that echoes many of the same points. The department’s letter also described requirements for a meaningful faculty role in competency-based education, including students’ ability to interact directly with instructors.

With two sides of the regulatory triad that oversees higher education having weighed in (states are the third), experts said colleges have clearer guidance as they seek to create competency-based programs.

“It’s designed to provide clarity for our institutions,” Barbara Brittingham, president of the higher education commission of the New England Association of Schools and Colleges and chair of C-RAC, said of the accreditors’ four-page guidance document.

Both the feds and regional accreditors included some basic definitions about competency-based education.

For example, the accreditors described relatively new competency-based programs that do not rely on the credit hour standard — so-called direct assessment degrees. The document cites the department’s use of that term, and uses similar language about the approval process for direct assessment programs.

“They seem to be in synch,” said Deb Bushway, interim associate dean at the University of Wisconsin-Extension and former chief academic officer and vice president of academic innovation at Capella University, where she worked on competency-based programs.

The unusual degree of coordination between the feds and accreditors on the two documents could help smooth out the kinks in the department-backed experimental sites program on competency-based education. Experimental sites allow participating colleges to be exempt from certain rules for federal aid eligibility as they tinker with different approaches to higher education.

However, the experimental sites project on competency-based education has been sluggish at times, due in part to mixed messages from the department about the emerging form of higher education, which more than 200 institutions have begun offering or are seeking to offer.

For example, the Higher Learning Commission, which is the largest of the regional accreditors, recently froze its approval of new direct assessment programs.

The commission said it made that decision in response to enhanced expectations the department issued in December about the approval of competency-based degree tracks. The department’s Office of Inspector General also has been auditing the commission over its review of direct assessment programs. The accreditor said on its website that it would await clearer guidance from Washington.

“HLC has determined it must wait until receiving those guidelines before changing its protocols for review of direct assessment and establishing new protocols for review and approval of competency-based education,” it said. “HLC will provide new protocols as quickly as possible after we receive the guidelines from the department.”

The commission was glad to get the six-page letter from the feds to accreditors, said an HLC spokesman. But more may be needed to free up the logjam of colleges that have applied to give competency-based education a try.

“We are waiting on clarification as to whether or not this will eventually apply to competency-based education as a whole or just to experimental sites,” the spokesman said via email. “Our being able to provide new protocols for our institutions will depend on that clarification.”

Defining the Faculty Role

Even so, experts said the similar language in the two documents will clear up some confusion.

“The more clear that the regional accreditors are, the better for the institutions,” said Laurie Dodge, vice chancellor of institutional assessment and planning and vice provost at Brandman University. Brandman is one of six colleges with a direct assessment program that has earned approval from both the department and a regional accreditor. Dodge is also co-chair of the Competency-Based Education Network (C-BEN), a Lumina Foundation-funded group that is comprised of institutions that either have competency-based degrees in place or are creating them.

The department’s letter describes what sort of quality review accreditors should conduct for competency-based programs that will be part of the experimental sites work.

In addition to describing what, exactly, constitutes a direct assessment program — which has been an area of confusion for some — the department’s letter touches on the faculty role in competency-based programs, many of which are online only.

The part faculty members play can be different than in the traditional model, particularly when it includes elements of self-pacing, where students can progress as fast as they can master course material or successfully complete assessments.

Instruction in competency-based programs and, more broadly, in online education, has been an area of scrutiny by the Office of Inspector General, which has criticized the department’s approval of direct assessment degrees and raised questions about the potential rise of poor-performing versions of competency-based education.

Accreditors are in charge of determining whether a college provides “regular and substantive” interaction between students and instructors as part of a competency-based program, according to the feds.

The department’s recent letter describes what it means by regular and substantive. Students must have access to qualified faculty, meaning instructors with “appropriate academic credentials and experience in the applicable knowledge domain,” the letter said. And that access must be available to students who are struggling to master learning materials or objectives, according to the department, or for “any reason when the student wants to interact with a faculty member.”

The department also described what that interaction might look like.

“While individual students may elect not to initiate contact with qualified faculty, program design must include periodic contact by qualified faculty with the students,” the letter said. “Those contacts could be made through the use of email or other social media, but must create the opportunity for substantive interaction.”

Learning coaches, online tutors and other support can be offered, too. And the department said those staff members may even account for the majority of students’ support. But programs must provide access to a qualified instructor “at least when students need or want it.”

The letter said competency-based programs can use teaching assistants, such as graduate students, to assess and grade student work, as traditional higher education has long done.

Both documents include a focus on tracking learning outcomes. Amy Laitinen, deputy director for higher education at New America, has said competency-based education’s spread could help move the rest of the academy to better track what students learn.

“Could this signal a move to an outcomes-based approach?” she said. “I think it should.”

Brittingham said the collaboration between the group of regional accreditors and the department on competency-based education has been unusually intensive. She said C-RAC issued a similar guidance document on “best practice” in online education back in the 1990s.

Fred Hurst, senior vice president for extended campuses at Northern Arizona University, said he welcomed the new clarity from the regional accreditors. “It puts them on record.”

Northern Arizona enrolls about 500 students in its competency-based programs, Hurst said, with three new degree tracks on the way.

“We’re going full speed ahead,” he said.