At the intersection of financial aid, college culture, academic policy, long established practice, and the Registrar’s Office is the credit hour. As discussed in an earlier post, the credit hour is a unit of currency demonstrating academic activity or work. It is also the focus of recent federal regulation. The Department of Education made its proposal to change the rules of credit hours, and much more, in June of 2010 under the heading of “program integrity.”
These changes were part of an even larger set of regulations to oversee education. Following a period of comment and negotiation, the new rules were adopted with an implementation date scheduled for July 2011. Many institutions of higher education are now finalizing their academic calendars for the 2011-2012 academic year. The consequences of the law and its implementation are unknown.
The nub of the regulations were succinctly summarized by CHEA in November, 2010:
- Establish a federal definition of a credit hour that is consistent with the Carnegie Unit (“one hour of classroom or direct faculty instruction and a minimum of two hours of out of class student work each week for approximately 15 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”).
- Affirm that (1) credit hour determination is an institutional responsibility, (2) the definition is intended for federal purposes only, (3) the definition constitutes a minimum expectation and (4) credit hour policies and procedures will be reviewed by accreditors.
- Describe credit hour as “an amount of work represented in intended learning outcomes and verified by evidence of student achievement,” establishing a “quantifiable minimum basis” and as a means to “quantify academic activity for purposes of determining federal funding.”
- Do not require institutions to adopt USDE’s definition of a credit hour in lieu of existing institutional measurements.
- With regard to accreditation, require these organizations, as part of accreditation reviews, to evaluate the reliability and accuracy of the institution’s assignment of credit hours and take action to address any deficiencies identified. Accreditors must report to USDE systematic noncompliance by institutions regarding criteria for assigning credit hours. Failure to do so may result in USDE restricting or removing the accreditor’s recognition.
In sum, institutions must use the federal definition of credit hour as their starting point for making academic judgments about the credits associated with courses and programs if the schools are to continue to be eligible for federal funding such as student aid. It should play out in an assurance from IHE’s that a traditional semester, three-credit course meets at least 37.5 hours or demonstrates equivalent instructional time.
Unsurprisingly, the regulations have generated commentary (here and here are two examples), as well as a recent letter of complaint from 60 educational organizations. The regulations are criticized as interfering with state law and possibly hindering legitimate efforts in distance education.
For legitimate institutions of higher education, the new regulations add an additional burden of reporting and accountability. They are troubling, like all unfunded mandates, for those on the ground who must document and track. They are more troubling for all in higher education, for what they tell us about government’s decreasing confidence in higher education’s ability to regulate itself. It is, unfortunately, an understandable reaction. We do not do a good job regulating ourselves. We do not look closely at credit hours in higher education, except when it comes to transfer students, and even then we focus on the transcripts of individual students, not institutional practice. Nor have I heard of an organization eager to take up this investigatory challenge. Accreditation does many things, but this sort of work is a stretch.
One of the reasons that we do not investigate ourselves is that there is precious little return on investment. No cultural capital accrues to the faculty member or administrator who looks to pressure institutions that have weak standards. In fact, it is very difficult for a faculty member or administrator to do within their own institution. There are no awards or prizes for whistle blowers and no recognized heroes who have demonstrated the courage and made the sacrifice. Sadly, we seem to need an external goad to keep us, the broader range of institutions of higher education, honest. Until we make this work our own, I expect to see an ever-increasing number of regulations imposed.