ERIC Identifier: ED446329
Publication Date: 2000-07-00
Author: Bobby, Carol L. - Capone, Lucien, III
Clearinghouse on Counseling and Student Services Greensboro NC.
Understanding the Implications of Distance Learning for
Accreditation and Licensure of Counselor Preparation Programs. ERIC/CASS Digest.
Accreditation and licensure standards, which have been built around the
traditional classroom paradigm for delivery of higher education, must shift
radically to accommodate the use of new distance learning technologies.
Furthermore, the movement from teacher-centered to learner-centered environments
results in a need for the accreditation and licensure paradigms to be
reevaluated in order to (1) remain relevant, (2) carry out their original
functions of accountability, quality assurance, and consumer protection, and (3)
not impede the development of distance learning programs.
THE NEED FOR OUTCOMES ASSESSMENT
have traditionally evaluated identifiable physical facilities,
faculty-to-student ratios, library holdings, support staff, and budgets as well
as course syllabi, faculty credentials, history of graduates, and the like.
These types of standards are collectively referred to as inputs assessment and
measure the capacity of an institution or program to carry out its educational
mission. But, are these standards relevant in a distance learning environment?
For example, in the case of a virtual university how would an accreditation site
visit be meaningful when all the accreditor will see are offices full of humming
and whirring computer disk drives? Faculty-to-student ratios have little meaning
when any number of students can pursue an on-line course without time and place
constraints. There also may be no library to visit if access is provided either
to computerized databases or to libraries by way of the Internet.
In the 1980s, some farsighted accreditors began shifting from inputs
assessment to outcomes assessment standards that evaluate the success of the
institution or program in accomplishing its mission. More specifically, outcomes
assessment evaluates how well the institution or program transfers knowledge and
skills to students. However, there has been resistance to this shift and
progress has been slow. First, it is harder to do. It is much easier to count
faculty, clock hours, and review budget figures than it is to determine if those
inputs are leading to successful outcomes. Second, some view inputs standards as
tools for protecting faculty lines, workloads, and resources -- a position that
often infuriates administrators. Third, outcomes assessment has been viewed as
the province of agencies that certify or license individuals to practice.
But these objections are based on an unnecessarily narrow view of outcomes
assessment that, if done correctly, can perform the critical function of
determining whether changes are needed in the inputs. Additionally, there is
growing pressure from the U.S. Department of Education (1997) and the Council
for Higher Education Accreditation (1998) to require validation of standards in
terms of relevancy to outcomes. Finally, since distance learning defies the
application of many traditional input standards, it will force accreditors in
the direction of outcomes assessment. When learning occurs via new delivery
methods, accreditors must ask new questions regarding what constitutes quality
education. They must review their existing standards against these questions and
revise the standards to insure quality within the new learning paradigm. Such
questions include the following:
First and foremost, what is being accredited? Is it an institution, a program of
study, a delivery system, or something else?
Who are the faculty? What support is provided to faculty who engage in distance
Who are the students and how are they evaluated? How do students interact with
faculty? Is the delivery system accessible to disabled students?
What instructional designs best fit with the mode of education delivery? How are
labs and clinics conducted?
What library facilities are available?
How is privacy of student data, verification of student identity, and protection
of intellectual property secured?
Once the fundamental questions have been answered, standards should be
examined to determine if they adequately assess the appropriate factors without
LICENSURE AND REGULATION OF DISTANCE LEARNING
collegial peer process that lies at the heart of accreditation, licensure of
educational institutions and programs is usually conducted by bureaucrats under
legislative mandate. There is nothing collegial about it. Although licensing
laws prescribe "standards," these differ from accreditation standards in that
they focus on amenability to legal process, fiscal accountability, and
compliance with state and federal laws. However, accreditation and licensure
have become commingled because many licensing laws require accreditation as a
condition of licensure.
Because each State has legal authority to regulate education within its own
borders, there are at least 51 different regulatory schemes (including the
District of Columbia's) with which a distance learning program may have to
contend just to operate within the United States. This multiplicity of
regulations presents difficult problems for distance learning programs desiring
to offer courses across jurisdictional lines. Identification of the applicable
regulations, multiple applications and fees, periodic audits and reporting to
each jurisdiction are just a few obstacles to be overcome (Western Governors
Association Design Team, 1996). Identifying a state's regulations can be
daunting because most states make no explicit mention of distance learning in
their regulations. Reference must be had to broader rules governing out-of-state
and nonpublic educational institutions. After the relevant set of regulations
has been identified, it is not always clear that those regulations will even
apply to a given distance learning program. In most states the institution must
have some physical presence within the state before the requirements apply. But
the definition of physical presence varies widely. Many states exercise
jurisdiction only if faculty or administrative personnel are present within the
state (Goldstein, 1998). Others exercise jurisdiction if academic credentials
are granted to residents within the state. A few assert jurisdiction if
instruction is given to state residents by correspondence, telecommunications,
or electronic media.
The scope of regulation varies also, ranging from simple registration of
institutions and programs to requiring that highly specific standards be
addressed within a complex application process. An example of the latter is
Florida, which requires a four-step process moving from temporary licensure to
"provisional level one" to "provisional" and finally to "regular" licensure.
Accreditation could provide a valuable service in reducing these regulatory
burdens if licensing agencies would accept accreditation as satisfaction of most
licensing requirements. This approach pares down those requirements to such
things as providing the address of a registered agent for service of process,
proof of insurance, and other such guarantees of legal and public
The historical reason for accreditation and
licensing in the United States has not changed. The public's need for reliable
information about education programs is even greater in the distance learning
environment. Accreditors should be empowered to think creatively and
cooperatively, so their standards and processes remain relevant and foster the
development of quality distance learning programs. The following recommendations
1. Rewrite standards to make them outcomes versus inputs oriented.
Accreditors should review standards to determine if they unnecessarily impede
innovation in the design and implementation of nontraditional delivery systems.
Standards should be written to assess outcomes rather than inputs.
2. Educate the public about accreditation of distance learning. As the
Internet makes it easier for fraudulent diploma mills to prey on the public
(Guernsey, 1997), accreditors must recognize that the demand for information
will not go away. Accreditors must educate the public about their standards and
quality assurance processes and inform them about questions they need to ask.
3. Encourage cooperation and collaboration between and among accrediting
agencies and licensing authorities. Accreditors and licensing agencies should be
encouraged to cooperate to reduce duplication of effort by educational programs
that cross regional or programmatic boundaries. Laws could be rewritten to
accept accreditation as satisfying some licensing requirements.
Because the paradigm for delivery of higher
education is shifting so markedly in the distance learning environment,
accreditors and licensure authorities will face new challenges in determining
what constitutes quality education. Standards that have traditionally quantified
inputs must be altered to measure student learning outcomes. However, knowing
where, when, and how to alter standards is not easy. Accreditors and licensing
authorities have had little time to define what constitutes good practices and
standards for distance learning programs. It is imperative that accreditors and
licensing authorities immediately begin working together to create a quality
assurance system that is relevant to new learning environments and protective of
the public's interest.
Council for Higher Education Accreditation.
(1998, September 28). Recognition of accrediting organizations: Policy and
procedures. Washington, DC: Author. (Available from CHEA, National Center for
Higher Education, One Dupont Circle, NW, Suite 510, Washington, DC 20036-1135)
Goldstein, M. B. (1998, June). Regulatory implications of distance learning:
The external environment. Paper presented at the annual conference of the
National Association of College and University Attorneys, Philadelphia, PA.
Guernsey, L. (1997, December 19). Is the Internet becoming a bonanza for
diploma mills? The Chronicle of Higher Education, pp. A22-A24.
U.S. Department of Education Procedures and Criteria for the Recognition of
Accrediting Agencies, 34 C.F.R. SS 602.20-.30 (1997).
Western Governors Association Design Team. (1996, July). The policy
environment for implementing the Western Governors University. Denver, CO:
Author [On-line]. Available: http://www.wgu.edu/wgu/about/policyenviron.html.%20