April 26, 2011
Secretary Arne Duncan
U.S. Department of Education
LBJ Building, Suite 7W300
400 Maryland Avenue, SW
Washington, DC 20202
Dear Secretary Duncan:
We know college completion and making higher education more affordable are key goals for you, the Education
Department you lead, and the entire Administration. Your leadership in promoting these goals is also consistent
with our mission here at the Foundation to make sure more low-income Americans graduate with credentials
that have labor market value, and we have been pleased to work with you and your team in promoting our
shared objectives in both K-12 and higher education.
That is why we are concerned about the new program integrity rules the Department will begin enforcing later
this year on credit hour and state authorization, and their potential effects on our grantees and innovation in
American higher education generally. While we understand the need to promote accountability and to weed
out bad actors in higher education, we fear these rulesin particular will have negative consequences on our
grantees, and limit the ability to scale the innovations we and others in the philanthropic sector have helped to
seed. In addition, we fear these rules may make higher education more expensive and erect other hurdles to
graduation for many of the same students the Administration and the philanthropic community aim to serve.
This letter requests clarity for some of our grantees that are implicated by these new rules, and offers potential
areas of partnership between the Foundation and the Department on these important issues.
Credit Hour: In the past, we have mentioned our specific concerns on the credit hour rule in particular to
members of your staff, who expressed interest in learning more about our grantees who might be harmed by
this new regulation, and we outline some examples below. In his recent Dear Colleague letter on this issue,
Assistant Secretary Ochoa states, "...At its most basic, a credit hour is a proxy measure of a quantity of student
learning." But for many of the colleges and grantees we support, how to measure and quantify student learning
are areas they are trying to revolutionize, in order to break the supposed link between learning and a required
number of credits or courses. Several of our grantees, like CUNY, the Open Learning Initiative at Carnegie
Mellon University, and the National Center for Academic Transformation are trying to accelerate time to degree
for students, especially in first-year courses, by using assessments and other tools to validate competencies and
move students though as quickly as possible once they have mastered content.
For example, CUNY is creating a separate college to focus on producing more graduates from at-risk
backgrounds. CUNY's experience is that attrition rates are worst for first-year students, especially at-risk
students, and have based the first year of study at the new college on cracking this problem. The new CUNY
college will enroll students full time in a course of study with no pre-determined credit value. The number of
credits that students earn will be based on measuring the content and quality of modules that students
complete successfully, using assessments and other tools. There will not be formal credit hours as that model
has been shown not to work successfully for many CUNY students. This new approach focused on measuring
learning will allow students to take the time they need to master content and maximize the credit accumulation
within a semester for students who can move forward more quickly. How will the Department and the
accreditors it recognizes treat programs like CUNY's? We fear that while the Department says it does not mean
to trample on innovation, the practical effect of the credit hour regulation will be to reinforce the existing credit
hour model, because it is easier for schools to conform to it rather than taking on the regulatory uncertainty
from both the Department and accreditors for experimenting in ways like CUNY envisions.
We also fear that the credit hour regulation will provide incentives to retain the current, unsustainable cost
structure in higher education. For example, we support a project with the National Center for Academic
Tra nsformation (NCAT) called Changing the Equation (http://www.thencat.org/Mathematics/CTE/CTE.htm),
which works with 38 community colleges around the country to redesign their developmental math curricula.
As you know well, developmental and remedial courses are both costly and where so many students fail to
advance. With Changing the Equation, each college will measure learning outcomes in their remedial math
courses using NCAT's proven redesign model which has been deployed in schools around the country. Student
success rates have increased 30% in initial pilots. Each institution participating in Changing the Equation will
both improve student learning outcomes and lower costs by reducing the number of remedial math courses
offered and students enrolled in them. Currently, the cost to deliver developmental education in thetraditional
format is $22.5M annually at the 38 participating schools (based on salary data). In August 2010, President
Obama cited one of the participating community colleges and its remedial math program saying, "...and that
means looking for some of the best models out there. There are comm unity colleges like Tennessee's Cleveland
State that are redesigning remedial math courses and boosting not only student achievement but also
graduation rates. And we ought to make a significant investment to help other states pick up on some of these
models." http://www.mystatlab.com/btog post/1048/obama-renews-hjs-ed ucationa!-goa s-nation]
By adopting the curricula redesign work alone, NCAT projects annual savings of $4.8M or 21 percent based on its
past work with other schools. But like CUNY, the NCAT model is based on accelerating students as quickly as
possible once they have mastered content. This model could provide practical solutions to colleges and state
policymakers to save money in the current fiscal environment while promoting better outcomes for students,
but how will the Department and accreditors treat this model which moves away deliberately from the credit
hour model to measure actual learning?
Like the Administration, we also have an interest in open educational resources. Along with other partners in
the philanthropic community, we support the Open Learning Initiative (OLI) at, Carnegie Mellon University. OLI
creates web-based courses that are designed so that students can learn effectively without an instructor. In
addition, the courses are often used by instructors to support and complement face-to-face instruction. An
independent evaluation found that statistics students taking OLI courses through hybrid face-to-face and online
instruction learned a full-semester's worth of material in half as much time and performed as well or better than
students learning from traditional instruction over a full semester. We are supporting OLI's expansion to see if
these results hold when implemented at scale, but again, in the current regulatory environment, what
confidence would a school have to experiment with this promising program as it deliberately innovates away
from the credit hour model? And how does an accreditor treat schools that pursue OLI? Despite the recent
Dear Colleague letter, our grantees remain unclear and uncertain about these important questions.
We know the Department does not oppose these innovative learning options that both accelerate time to
degree and reduce costs for students. However, our grantees tell us and we believe that the unintended effects
of the credit-hour regulation will lead to perverse incentives that create uncertainty for both schools and
accreditors. This uncertainty may very well hurt the ability to scale these promising interventions, and reinforce
a credit-hour model that makes it more difficult and costly to innovate. We request that the Department clearly
answer the questions outlined in this letter so that our grantees, other colleges, and accreditors realize that the
specific examples we have cited are permissible.
State Authorization: Regarding the new state authorization rule, the Department's other recent Dear Colleague
letter on this topic which provides more flexibility to online institutions will be especially helpful to a number of
grantees we support. We are working currently with a group of online public and non-profit private colleges to
expand across state lines. We believe greater competition in online higher education will help bring down costs
for students and states, and allow different types of online and hybrid education to proliferate, like competencybased
education. The schools we are working with include Rio Salado College, University of Maryland-University
College, Penn State World Campus, Western Governors University, and UMass Online.
In closing, we would be happy to work with the Department, states, education experts, and our partners in the
philanthropic community to plan for development of a common state application for licensure of online
programs, so that competition in online education is not hampered, students are able to complete degrees they
have started, and additional costs colleges incur to receive licensure in multiple states are not passed on in the
form of higher tuitions. And we also request that you provide clarity on the credit hour regulation and its effects
on the three examples from our grantees that are outlined above. We remain committed to working with you
and your Department on issues of common interest, such as the ones addressed in this letter. Please let me
know how I can be helpful to you on these topics that are central to our ability to graduate more students, lower
costs, and improve productivity in higher education.
Sincerely,
Hilary Pennington
Director of Education, Postsecondary Success & Special Initiatives
U.S. Program
Bill & Melinda Gates Foundation
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