Application and QA questions 2015-10-06 final

OMB Number: 1845-XXXX

Expiration Date: XX/XX/XXXX

Experimental Site: Educational Quality through Innovative Partnerships (EQUIP)

Information Collection Request

Overview

Through the Department of Education’s (the Department) Educational Quality through Innovative Partnerships (EQUIP) experiment, the Secretary will provide a limited waiver of the requirements, under the Higher Education Act of 1965, as amended (HEA), that an ineligible institution or organization cannot provide 50 percent or more of a title IV-eligible educational program, and that an eligible program must be provided by a participating institution. For this experiment the Secretary will also waive, as needed, other requirements related to the minimum timeframes for eligible programs and the timeframe and method of calculating a student’s academic progress. The experiment is described fully in a Federal Register notice which is available in the Federal Register Section of the Information for Financial Aid Professionals website, ifap.ed.gov.

The Department will select a limited number of postsecondary institutions (institutions) to participate in this experiment. As described in the Federal Register notice, interested institutions will be invited to submit a brief initial letter of interest. If all of the institutional qualifications for participation are met and the Department determines the initial letter to be of sufficient quality and in alignment with the goals of the experiment, the institution will be asked to submit a full application, based on the questions outlined here.

This information collection instrument is intended to gather information that will assist the Department in selecting a set of qualified and diverse institutions for participation in this experiment. Please provide thorough responses for each of the prompts below.

Note: Several of the items below ask for information at the educational program level. If any responses will differ by program, please indicate the differing information for each of those programs. If the response to an item is the same for all programs, one response is sufficient.

Full Application Information

Please include in the application the following information about the educational program(s) of study that the institution intends to include in its participation in the experiment.

I. Program Focus and Description

1. Description of the program(s) of study

1. What certificate, degree, or recognized credential will the program award to graduates? If a certificate or other non-degree credential, will it count as credit toward a degree at the institution?

2. What types of measurable student outcomes will the program strive to achieve (e.g., specific learning outcomes, academic transfer credit, job placement)?

3. What is the program’s academic structure?

• How will the curriculum be structured? For example: Will the program be offered in courses or in modules?  Will the program start at the beginning of the term, monthly, or individualized by student?

• What will be the program’s duration (e.g., semester(s), quarter(s), academic year(s), weeks)? Will the program track credit hours or clock hours, and how will it calculate those hours? How will the federal satisfactory academic progress requirement be calculated and tracked?

• What will be the instructional method and approach (e.g., face-to-face, online, or hybrid; competency based; self-paced)? Will it include experiential requirements such as internships or other components?

• How will the components be integrated into a coherent and meaningful credential?

1. How will the program be designed to offer better value or outcomes than other programs that currently exist (e.g., lower cost, more flexibility/personalization, increased labor market value and/or transfer value)? Please provide quantifiable goals where applicable (e.g., how much of a lower cost or higher value?).

2. What is the market demand for this program (e.g., students or employers willing to pay full tuition and fees)? How was this market demand determined?

3. Please provide information about the costs of the program:

   • What is the total tuition and fee amount that will be charged per student for the entire program?

   • What is the expected net price for the student after grants and other gift aid are subtracted?

4. Is the non-traditional provider in this partnership a for-profit entity?

5. If an existing program will be adapted for the proposed program, provide answers to the following questions about the existing program:

• Is the existing program provided by the institution or by the non-traditional provider?

• Will that version of the program continue to be offered while an alternative version participating in the experiment is also offered?

• Will the institution or the non-traditional provider also be offering a version of the program that is not Title-IV eligible while participating in the experiment?

• What is the total tuition and fee amount that is charged a student for the existing program?

• How many students were enrolled in the existing program in the most recent year?

• To the extent that information is available, provide the percentage of students who relied on private loans to cover all or some of the tuition and fees charged for the existing program

• To the extent that this is applicable and there are publicly available documents that provide this information, what were the total profits generated by this program or service in the most recent year?

2. Anticipated student population

1. What is the estimated number of students in the program in its first year?

2. Describe the target student demographics (e.g., race/ethnicity, age range, prior academic credit or credentials, work experience, family income). Please specify the expected number and percent of Pell-eligible students.

3. What are the estimated proportion of students in the program who would receive title IV aid, estimated proportion of students in the program who would receive Veteran’s educational benefits, and the estimated total proportion of students in the program receiving one or the other or both?

3. Will the program allow otherwise eligible students in the ex-site to receive 1) only Federal Pell Grant funds, or 2) Pell Grants as well as undergraduate Direct Subsidized Loan, undergraduate Direct Unsubsidized Loans, and aid from the Campus-Based Programs?

4. What are the expected benefits to the students for completing the program (e.g., transfer credit, certifications earned, completion of licensure exams, externally validated skills and knowledge, employment, salary increase)? Please cite specific data or studies, where they exist, to demonstrate that the program leads to the expected benefits.

5. What will be the roles and responsibilities of the institution and the non-traditional provider(s)? For example, who will develop content; market the program; advise students; provide instruction; provide support services; develop and administer assessments for students; and collect and validate information on student outcomes?

6. If the institution will provide payment to the non-traditional provider, on what basis will the amount of the payment be determined?

7. What is the track record (e.g., measurable student outcomes such as academic or employment outcomes) of the non-traditional provider(s) with respect to serving low-income students? If the provider has not served low-income students in the past, please provide: 1) measurable student outcomes for all students served by the provider, and 2) a detailed description of how the program would be tailored to help low-income students succeed.

8. What is the track record of the institution with respect to serving low-income students?  In the response, please include the Pell completion rate that the institution is required to disclose to enrolled and prospective students per 34 C.F.R. § 668.45.

9. What support services does the institution already have in place for low-income students? Do these supports and services need to be adapted for this program?

10. For institutions choosing to allow access to Pell Grants and other title IV aid (as listed above), how will the institution award Campus-Based aid in a way that will remain consistent with the experiment’s focus on access for low-income students?

II. Quality Assurance Process

1. Description of the quality assurance entity (QAE)

1. What entity will be the QAE and what experience, expertise, and skills will it bring to this role? What information gives the institution confidence that the QAE will meet all the requirements of this experiment, including the capacity to address the “Quality Assurance Questions” (listed below)?

2. By what process has the QAE developed (or will develop) clear, specific, and measurable standards by which to review, approve, and monitor programs based on the “Quality Assurance Questions,” establish consequences, and enforce the standards?

3. How will the QAE review programs based on the “Quality Assurance Questions”? Has it already reviewed the program based on those questions? If so, attach specific answers. If not, when will it do so? (Please note: these questions will need to be answered by the QAE before the Program Participation Agreement for the participating institution is amended.

4. How will the institution, QAE, and/or accreditor monitor and report on the performance of the program, providers, and students? How will the QAE be linked with the institution’s and accreditor’s existing complaint processes? If the QAE identifies program quality concerns or determines that the program is at risk of or subject to any adverse action by any party, how will the QAE notify the institution and affiliated non-traditional providers?

5. What actions will the institution and/or QAE take, and under what circumstances, to hold the institution and the non-traditional providers accountable, and help them improve as necessary?

2. If the program is suspended, terminated, or otherwise limited in its participation in the experiment by the Department, the QAE, the accreditor, the institution, or the non-traditional provider(s), what academic options will be provided to students by the institution (e.g., full transfer of credits into another program at the institution, a title IV teach out plan, and/or other options)? For institutions allowing access to federal student loans as part of the experiment, what actions will the institution take, and under what conditions, to protect students from debt or other financial liabilities resulting from their enrollment in a program that is suspended, terminated, or otherwise limited (e.g., repayment of student loans, transfer of credit to another institution, free access to credit-bearing courses, etc.)?

3. What policies and procedures will be in place to assure the independence and absence of conflicts of interest among the non-traditional providers, QAE, and the institution? Please address independence in terms of ownership, funding, and staffing.

4. What due diligence has the institution done, or will it do, to determine if the QAE, non-traditional providers, and their employees are in good legal standing and have no past history of fraud, commission of a felony, disbarment or liability for negligence or misrepresentation?

III. Information Related to Specific Title IV Provisions

1. Will the program use the minimum program length waiver?

2. Will the program use the satisfactory academic progress waiver?

3. If the program is a distance-education program, how will it address the "regular and substantive interaction" requirements, or qualify as a degree-granting correspondence program?

IV. Provider and Accreditor Commitments

Please include letters from the non-traditional provider(s) and from the institution’s institutional accreditor confirming the following:

1. Non-Traditional Provider(s): Commitment to offer content and instruction once required approvals are secured.

2. Accreditation Agency: Agreement to consider including the proposed program in the institution’s accreditation. NOTE: A proposed program does not need to have been reviewed and included in accreditation at the time of this application; statement simply needs to express agency’s willingness to undertake that review.

Quality Assurance Questions

As part of this experiment, the Department is interested in understanding how a QAE will determine the quality of a program of study through a set of largely outcome-based questions, rigorous and timely monitoring, and accountability processes. Participating institutions must ensure that the QAE has established a thorough quality assurance process that defines and monitors outcome-based standards for each of the numbered questions below.

1. Claims for learning

1. What measurable claims is the institution making about the learning outcomes of students enrolled in the program? For example:

• What is the evidence that the learning claims are commensurate with postsecondary- or post-baccalaureate-level work?

• Do the institution’s statements about student outcomes capture requisite knowledge and skills? How?

2. How are the value and relevance of those claims established? For example, what external stakeholders have been consulted to verify the value and relevance of the claims?

3. How will the claims be measured?

4. How will institutions be held accountable for meeting those claims?

5. How do all the claims for learning come together into a meaningful and coherent set of overall program outcomes and goals?

B. Assessments and Student Work

1. How does the institution assess whether students enrolled in the program can meet the claims outlined in Section A? For example:

• How are assessments aligned with the specific tasks, expectations, and contexts for which programs claim to be preparing students?

• Beyond one-time assessments, is student work reviewed as part of the assessment of student learning and program outcomes? Do external stakeholders review students’ work? How are examples of student work made available to outside parties (with appropriate privacy and other protections)?

2. How has the reliability of these assessments been established?

3. How has the validity of these assessments been established, for example in terms of the following?

• Face validity: Does the assessment appear to measure what it says it measures?

• Content validity: Does the assessment accurately measure the knowledge and skills covered by the program?

• Predictive validity: Does the assessment accurately predict the student’s ability to demonstrate a given competency in the future?

• Concurrent validity: Does the assessment correlate with other measures of the desired performance meant to be assessed?

4. How and how often does the QAE review these assessments?

C. Outputs, which, where applicable, must be disaggregated to show outcomes specifically for low-income students.

Note: At the time of application for this experiment, the application should include a description of how the QAE will track these outcomes (specific measures and process) and what level would meet the quality standard for each outcome. If the non-traditional provider(s) have gathered this data for an existing version of the program to be implemented, the application should also include those data. For all measures that reflect existing data, appropriate privacy protections should be applied.

1. How are students performing on program assessments?

2. How are students progressing through the program? For example:

• Retention rate?

• Withdrawal rate?

• Average time to completion?

• Completion rate (within 100 percent and 150 percent of expected time)?

3. What are the actual program outcomes for students (e.g., entry into subsequent phase of study, career, etc.)? For example:

• Employment outcomes, for all programs that have a stated mission focused on employment (include method for how these outcomes are measured):

  • Job placement rates in field of study?

  • Average length of time between completion of program and employment in field of study?

  • Job retention rates?

  • Median starting salaries?

• Transfer rates to other academic or vocational programs, where applicable

• Certifications and licensure exam passage rates, where applicable

4. What are the following ratios for the program, where relevant?

• Published tuition and fees versus earnings

• Average net price versus earnings

• Median student debt versus earnings

5. How does the program rate on measures of student satisfaction? For example, how does the program rate in the following:

• Comments from students about what made them successful or unsuccessful in the program?

• A rigorous and transparent methodology for gathering and synthesizing customer satisfaction measures?

D. Management

1. How has the stability of the non-traditional provider(s) been evaluated (e.g., longevity and past outcomes, leadership/board, etc.)?

2. How are privacy, security, and student authentication managed?

3. Are activities related to student recruitment appropriate and transparent?

4. How is pricing made transparent?

5. Are all materials accessible to learners with disabilities?

6. What is the process for continuous improvement of all aspects of the learning experience (content, platform, student support, faculty engagement, etc.)?

PRA Burden Statement

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless such collection displays a valid OMB control number. The valid OMB control number for this information collection is 1845-XXXX. Public reporting burden for this collection of information is estimated to average 80 hours per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The obligation to respond to this collection is required to obtain or retain a benefit (Section 487A(b) of the Higher Education Act of 1965, as amended). If you have comments or concerns regarding the status of your individual submission of this information, please contact Experimental Sites at experimentalsites@ed.gov directly.

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