The U.S. Department of Education’s Office of Inspector General has released the results of a much anticipated high-stakes audit of Western Governors University, with negative findings that could threaten the large online university and, more broadly, the growing field of competency-based education.
Citing concerns about an inadequate faculty role — which the competency-based university contests — the inspector general called for the department to make WGU pay back at least $713 million in federal financial aid.
The final audit report, issued today, also said the nonprofit university, which enrolls 83,000 students, should be ineligible to receive any more federal aid payments.
Experts said the Trump administration is unlikely to follow through on the inspector general’s recommendations, which the department can reject. The department has signaled that it will be a less aggressive regulator than it was under the Obama administration.
WGU enjoys a good track record with its accreditor and broad bipartisan support in Washington, with the Obama administration having often praised the university as an innovator.
The findings of the audit, which began more than four years ago, were not a surprise to most observers.
That’s because the inspector general relied on a 1992 federal law that defines aid eligibility for distance education programs, which many have said poses a problem for WGU, some other competency-based programs, and possibly online education writ large.
The audit report said most courses at WGU do not meet the distance education requirement because they were not designed for regular and substantive interaction between students and faculty members. Those courses instead should have been labeled as correspondence courses, according to the inspector general.
Under the law, a college is not eligible to receive federal financial aid if more than half of its courses are offered via correspondence or if most of its students are enrolled in correspondence courses. The inspector general’s audit report said 62 percent (37,899) of the 61,180 students who were enrolled at WGU in 2014 took at least one of 69 courses (among 102 courses in the university’s three largest academic programs) that failed to meet the distance education requirements.
“None of these 69 courses could reasonably be considered as providing regular and substantive interaction between students and instructors, the key requirement to be considered a course offered through distance education,” according to the report. “Therefore, Western Governors University became ineligible to participate in the Title IV programs as of June 30, 2014.”
As a result, the inspector general said the department should require WGU to return $713 million in federal aid it received during the two years before July of last year, as well as any federal aid it received since then.
The university rebutted the report, both in responses to the inspector general that were included in the final report and on its website.
“Western Governors University respectfully, but strongly, disagrees with the findings in the Office of Inspector General’s draft audit report. WGU is, and has always been, fully compliant with Department of Education regulations since our founding 20 years ago by 19 U.S. governors,” the university said in a May letter to the inspector general. “Our innovative learning model, which has the support of the law, the department, our accreditor and policy makers, is validated by the outcomes WGU is delivering for our 82,000 students and 81,000 graduates.”
Unbundled Faculty Model
In previously released audits, the inspector general has questioned whether some competency-based programs should be classified as being of the correspondence variety. Others have criticized the department and accreditors for their scrutiny of competency-based programs, particularly those that do not rely on the credit-hour standard.
WGU uses the credit-hour standard, even though the U.S. Congress passed a law exempting it from certain requirements relating to the standard.
However, the inspector general found that the university’s unbundled (or disaggregated) faculty model, which is considered one of its primary innovations, runs afoul of federal distance education requirements.
Students at WGU are assigned a faculty member, called a student mentor, when they first enroll. Faculty mentors have at least a master’s degree in their field and are well versed in students’ program requirements, the university said. Mentors work with students regularly until they graduate.
The university also employs a Ph.D.-holding subject matter expert for each course, dubbed the course mentor. These faculty members interact with students as well. In addition, subject matter experts oversee each program of study at WGU. (Students must enroll in a program at the university, not just in individual courses.) And the university employs faculty evaluators, who review competency assessments.
The inspector general, however, found that “only course mentors and evaluators, not student mentors, product managers or council members, could reasonably be considered instructors.”
The report also said interactions between students and instructors were inadequate under the federal law.
“The course design materials for all 69 of these courses described courses that would be self-paced, interaction between the students and instructors that would primarily be initiated by students, and interaction between the students and instructors that would not be regular and substantive,” according to the inspector general. “The course design materials described limited interaction with course mentors that was typically on an as-needed basis and typically initiated by the student. Therefore, we concluded that the school’s faculty composition model did not ensure that the school’s courses were designed to provide the regular and substantive interaction between students and instructors required by the Title IV definition of distance education.”
In an interview, Scott Pulsipher, WGU’s president, said the inspector general’s report was based on a “misinterpretation and misapplication” of statutory and regulatory guidance.
“We vehemently disagree with the inspector general’s opinion,” he said. “We’ve been compliant with the laws and regulations since our founding.”
Pulsipher noted that the university’s regional accreditor, the Northwest Commission on Colleges and Universities, backs the university’s faculty model. And he said the inspector general had applied a “very narrow and tight definition of faculty” at the university, compared to the approval by its accreditor and other regulators of WGU’s varied and broad faculty roles.
Congress could intervene by changing the 1992 federal law, as some backers of WGU and competency-based education have been advocating. The university will work with federal and state policy makers, Pulsipher said, to address ambiguity in the law.
“We’ll work together to make sure it gets clarified,” he said.