Distance Education Policy

I. Scope

This policy applies to William & Mary (W&M) as a whole university, including the School of Marine Science at Virginia Institute of Marine Science.  The policy is applicable to all credit-bearing distance learning courses and programs offered by W&M, including both asynchronous and synchronous courses that are fully online and those that employ distance education instructional methods. The policy is also applicable to all individuals teaching distance education courses for institutional credit, as well as to all W&M students.

II. Purpose and Policy Statement

The purposes of this policy are to: (1) define distance education; (2) establish minimum requirements regarding regular and substantive interaction between instructors and students in distance education courses; and (3) establish minimum requirements regarding the verification of student identity in distance education courses at W&M. This policy aligns with definitions and provisions within the U.S. Code of Federal Regulations, the Virginia Administrative Code, and the requirements of the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC) concerning distance education.

III. Definitions

W&M’s definition of distance education aligns with the Code of Federal Regulations in 34 C.F.R. 600.2, the Virginia Administrative Code in 8VAC40-31-10, and the Distance Education and Correspondence Courses Policy Statement of the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC).

Distance education means a formal educational process of providing planned teaching and learning activities to deliver instruction when instructors and students are in different locations, whether the instruction and activities occur synchronously or asynchronously.

Online means “by means of the internet or other computer network.” 

Online course means a course in which all learning and assessment activities for the course are provided online.

Synchronous Online Courses means courses in which faculty and students meet via online technology at scheduled times in a live, “in-real-time” framework, much like in-person courses meet. These courses require student participation at a set time each week, and they allow for real-time communication, discussion, and interaction between faculty and students. The required weekly meeting time(s) for synchronous courses must be disclosed prior to student registration in the course.

Asynchronous Online Courses means courses that do not have required meeting times, though they may include optional live electronic meetings and/or virtual office hours. Asynchronous courses generally employ flexible schedules with weekly deadlines, allowing students to complete the week’s coursework at times within that week that work for their own schedules.

Online program means a program for which all courses required for completion of the program are available as fully online courses. Exceptions to this requirement include short-term in-person capstone/practicums/other similar required courses. Such exceptions must provide added educational value, must be approved by the Dean of the primary academic unit (school), and must be made clear to potential students prior to their enrollment in the program.

Direct instruction, in alignment with The Glossary of Education Reform, means instructional approaches that are structured, sequenced, and led by qualified instructors, and/or the presentation of academic content to students by qualified instructors. Examples of direct instruction include synchronous class sessions, intentionally sequenced course modules, and instructor-created or instructor-selected videos that are relevant to the content.

Substantive interaction, according to 34 C.F.R. 600.2, means instruction that engages students in “teaching, learning, and assessment, consistent with the content under discussion,” and also includes at least two of the following:

1. Providing direct instruction (see definition above);
2. Assessing or providing feedback on a student’s coursework;
3. Providing information or responding to questions about the content of a course or competency;
4. Leading or facilitating discussion forums or group discussion regarding the content of a course or competency;
5. Providing information, content, and asynchronous activities through announcements, e-mail, media, and/or other relevant technologies;
6. Providing and engaging in other instructional activities outlined by a program’s accrediting agency.

Regular interactions, according to 34 C.F.R. 600.2, means interactions that (1) provide opportunities for substantive interactions between the faculty member and a student on a “predictable and scheduled basis commensurate with the length of time and the amount of content in the course;” and (2) demonstrate that an instructor “promptly and proactively engag[es] in substantive interaction with the student” when needed based on the instructor’s monitoring of the student’s academic engagement and success, or upon request by the student.

IV. Policy

A.    Distance Education

1. Courses which do not meet this policy’s definition of an online course but plan to employ instructional elements meeting the definition of distance education are subject to this policy. All distance education components of such courses must comply with the requirements of this policy.

2. Regardless of the mode of delivery, all courses offered for W&M credit must meet the requirements of W&M’s Academic Credit Hour Policy.

3. Distance education courses covering the same content at the same level and receiving the same number of credit hours as in-person courses must be demonstrably similar in course content, expectations, and workload.

4. All online courses and other courses utilizing planned distance education instructional methods must be able to demonstrate that they employ both substantive interactions and regular interactions.

5. Online courses can require in-person examinations or laboratories. In such cases, all in-person requirements must be included in the syllabus and must be communicated to all students prior to the end of the term’s add-drop period.

6. Faculty should use a variety of instructional strategies and resources to facilitate an engaging and accessible learning environment.

7. Educational technology tools and resources used for delivering content via distance education and for assessing student learning must:

• (a) Facilitate substantive and regular interactions between students and faculty;
• (b) Verify student identity (see below); and
• (c) Ensure course material accessibility. See W&M’s Course Accessibility webpage for information and resources

8. Educational technology tools and resources used for assessing student learning must:

• (a) Verify student identity (see below); and
• (b) Ensure course material accessibility. See W&M’s Course Accessibility webpage for information and resources.

9. Instructors of courses offered by distance education must meet the same instructor qualifications as those established by W&M for on-campus courses; see W&M’s Faculty Credentials and Qualifications and the W&M Faculty Qualifications Manual.

10. For online programs, courses must be offered frequently enough to enable students to progress through and complete the program in a timely manner. Any requirements for in-person participation must impart added educational value that cannot be achieved online. Information regarding any required face-to-face and on-ground/in-person work (e.g., practicums, internships, residencies,  specialized laboratory work, etc.) must be provided to students prior to their enrollment in the program.

11. Schools/primary academic units and departments or programs must notify the Office of the Provost and Office of Institutional Accreditation & Effectiveness prior to engaging in services with an outside partner that may provide recruitment and/or enrollment services (where there is direct contact with current or potential students), course design, student support and retention, student employment, and academic/student support services. Further, the following requirements must be met and must be documented, where possible, as part of a contract or similar memorandum of understanding between the outside partner and the W&M unit(s) involved:

• (a) W&M faculty retain control of the curriculum.
• (b) All individuals teaching courses int eh program must meet W&M's faculty qualification requirements as outlined in W&M's Faculty Credentials and Qualifications Policy and in the W&M Faculty Qualifications Manual.
• (c) Any non-W&M faculty must provide evidence of their qualifications and credentials, including transcripts and other documentation, as outlined in W&M’s Faculty Credentials and Qualifications Policy and in the W&M Faculty Qualifications Manual.
• (d) All appropriate library and learning/information resources must be made available to students.
• (e) All appropriate academic and student support services and physical resources must be made available to students. 
• (f) Recruitment materials and presentations must accurately represent the practices, policies, and accreditation status of W&M. Contact the Assistant Provost for Institutional Accreditation & Effectiveness for more information.
• (g) The online program management (OPM) provider and any other independent contractors or agents used for recruiting purposes, admissions activities, instructional engagement, etc. on behalf of W&M must be under contract with W&M and must be governed by the same principles and policies as institutional employees, including but not limited to the protection of student privacy and student data.

12. Responsibilities

• (a) Faculty hold primary responsibility over the content, quality, and effectiveness of courses and curricula, regardless of the instructional modality.
• (b) Faculty are responsible for delivering course content and for ensuring that their distance education courses meet course accessibility requirements. See W&M’s Course Accessibility webpage for information and resources.
• (c) Faculty shall ensure that each of their distance education courses meets this policy’s requirements regarding substantive interaction and regular interaction.
• (d) Faculty who teach distance education courses for W&M credit are responsible for ensuring they meet any school-specific training requirements related to providing distance education instruction. Further, faculty are responsible for ensuring that they have acquired necessary and appropriate skills for teaching effectively in a distance education environment. W&M’s Studio for Teaching and Learning Innovation (STLI) provides resources for faculty regarding online instruction.
• (e) Deans are responsible for making and implementing decisions regarding the instructional modality of courses being offered (or to be offered).
• (f) Deans are responsible for ensuring that the requirements of this policy have been met and that the availability of course offerings in various modalities align with student demand and program modes of delivery.
• (g) The Office of the Provost shall monitor university-wide compliance with this policy and shall ensure that Deans are informed of any changes in a timely fashion.  

B.    Verification of Student Identity

1. W&M ensures that a student who registers for credit-bearing distance education courses and/or programs is the same individual who participates in and completes the course or program and receives academic credit.  Distance education courses at W&M use one or more of the following methods to achieve this:

• (a) A secure login and password;
• (b) Proctored examinations; and/or
• (c) New or emerging technologies or practices that are effective at verifying student identity.

2. Students must never share their username and/or password with others. Further, students must not attempt to disguise their identity or the identity of their account or the device that they are using to engage in distance education course requirements. Use of technology such as masking an IP address or using VPN technology for the purpose of concealing one’s identity while engaging in course requirements for distance education courses is forbidden, and offenses are subject to penalty under the Code of Student Conduct/Honor Code.

3. Methods used to verify student identity in distance education courses and programs at W&M must ensure the privacy and protection of student information.

4. If any fees will be charged to students in distance education courses and/or programs for the purpose of verifying student identity, students must be notified of all charges in writing at the time of registration or enrollment.

5. For purposes of verifying student identity, W&M may collect and use personally-identifiable information, so long as the collection and use of said information is in compliance with applicable university policies and state and federal laws and regulations.

6.  Responsibilities

• (a) All users of W&M’s learning management systems and other technologies used for verifying student identity must maintain the security of usernames, passwords, and other access credentials assigned to them by W&M.  Such access credentials must never be shared with anyone other than the user to whom they have been assigned.
• (b) Users are responsible for all uses of their access credentials.
• (c) Users are responsible for changing passwords periodically to maintain the security of their access credentials and accounts.
• (d) Users are responsible for maintaining knowledge of university policies, guidelines, and requirements that are relevant to this policy. Failure to read these documents shall not exempt them from this responsibility.
• (e) Students must always provide complete and true information in any identity verification process. Failure to do so is a violation of the W&M Honor Code.
  (f) Faculty teaching distance education courses must ensure that their individual courses comply with the provisions of this policy.
• (g) Deans must inform the Office of the Provost, the Office of Institutional Accreditation & Effectiveness, and Information Technology of any new technologies for verifying student identity that are being used or are being considered for use within their schools/primary academic units or within individual courses taught by the faculty in their primary academic unit
• (h) Deans of schools/primary academic units shall ensure that faculty comply with this policy.
• (i) The Office of the Provost shall monitor university-wide compliance with this policy and shall ensure that deans are informed of any changes in a timely fashion.

V. Authority, Amendment and Implementation

This policy is approved by the Provost in accordance with Article X Section C of the Bylaws of the Board of Visitors and the Policy on Creating Whole University Policies & Procedures. 

VI.  Related Documents

Code of Federal Regulations, 34 C.F.R. 600.2
Virginia Administrative Code 8VAC40-31-10
Southern Association of Colleges and Schools Commission on Colleges (SACSCOC); Distance Education and Correspondence Courses Policy Statement
The Glossary of Education Reform
W&M’s Faculty Credentials and Qualifications Policy
W&M Faculty Qualifications Manual
W&M Course Accessibility webpage