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United States Government Accountability Office: GAO: 

Report to Congressional Requesters: 

November 2011: 

Higher Education: 

Use of New Data Could Help Improve Oversight of Distance Education: 

GAO-12-39: 

GAO Highlights: 

Highlights of [hyperlink, http://www.gao.gov/products/GAO-12-39], a 
report to congressional requesters. 

Why GAO Did This Study: 

As the largest provider of financial aid in higher education, with 
about $134 billion in Title IV funds provided to students in fiscal 
year 2010, the Department of Education (Education) has a considerable 
interest in distance education. Distance education—that is, offering 
courses by the Internet, video, or other forms outside the classroom—
has been a growing force in postsecondary education and there are 
questions about quality and adequate oversight. GAO was asked to 
determine (1) the characteristics of distance education today, (2) the 
characteristics of students participating in distance education, (3) 
how the quality of distance education is being assessed, and (4) how 
Education monitors distance education in its stewardship of federal 
student aid funds. GAO reviewed federal laws and regulations, analyzed 
Education data and documents, and interviewed Education officials and 
industry experts. GAO also interviewed officials from accrediting and 
state agencies, as well as 20 schools—which were selected based on a 
variety of factors to represent diverse perspectives. 

What GAO Found: 

While distance education can use a variety of technologies, it has 
grown most rapidly online with the use of the Internet. Online distance 
education is currently being offered in various ways to students living 
on campus, away from a campus, and across state lines. School offerings 
in online learning range from individual classes to complete degree 
programs. Courses and degree programs may be a mix of face-to-face and 
online instruction—“hybrid” or “blended” instruction. Online 
asynchronous instruction—whereby students participate on their own 
schedule—is most common because it provides students with more 
convenience and flexibility, according to school officials. In the 2009-
2010 academic year, almost half of postsecondary schools offered 
distance education opportunities to their students. Public 2-and 4-year 
schools were most likely to offer distance education, followed closely 
by private for-profit 4-year schools. 

Students in distance education enroll mostly in public schools, and 
they represent a diverse population. While they tend to be older and 
female, and have family and work obligations, they also include 
students of all races, current and former members of the military, and 
those with disabilities. According to the most current Education data 
(2007-2008), students enrolled in distance education studied a range of 
subjects, such as business and health. 

Accrediting agencies and schools assess the academic quality of 
distance education in several ways, but accreditors reported some 
oversight challenges. Federal law and regulations do not require 
accrediting agencies to have separate standards for reviewing distance 
education. As such, accreditors GAO spoke with have not adopted 
separate review standards, although they differed in the practices they 
used to examine schools offering distance education. Officials at two 
accreditors GAO spoke with cited some challenges with assessing 
quality, including keeping pace with the number of new online programs. 
School officials GAO interviewed reported using a range of design 
principles and student performance assessments to hold distance 
education to the same standards as face-to-face education. Some schools 
reported using specialized staff to translate face-to-face courses to 
the online environment, as well as standards developed by distance 
education experts to design their distance education courses. Schools 
also reported collecting outcome data, including data on student 
learning, to improve their courses. 

Education has increased its monitoring of distance education but lacks 
sufficient data to inform its oversight activities. In 2009, Education 
began selecting 27 schools for distance education monitoring based on 
an analysis of risk factors, but it did not have data to identify 
schools with high enrollments in distance education, which may have 
impeded its ability to accurately identify high-risk schools. Between 
2011 and 2013, Education’s National Center for Education Statistics 
(NCES) will start collecting survey data on the extent to which schools 
offer distance education, as well as enrollment levels. However, the 
department’s Office of Federal Student Aid (FSA), responsible for 
monitoring Title IV compliance, was not involved in the process of 
deciding what distance education information would be collected; 
therefore, it did not provide input on what types of data could be 
helpful in oversight. Further, FSA officials said they do not yet have 
a plan on how they will use the new data in monitoring. 

What GAO Recommends: 

To improve its oversight and monitoring of federal student aid funds, 
Education should develop a plan on how it could best use the new 
distance education data NCES is collecting and provide input to NCES on 
future data collections. Education agreed with the recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-12-39] or key 
components. For more information, contact George A. Scott at (202) 512-
7215 or scottg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Distance Education Has Become Common in All Sectors and Is Offered 
through a Range of Programs and Courses: 

Students in Distance Education Enroll Mostly in Public Schools and 
Represent a Diverse Population: 

Accreditors and Schools Assess the Academic Quality of Distance 
Education in Several Ways, but Accreditors Reported Some Oversight 
Challenges: 

Education Has Increased Its Monitoring of Distance Education but Lacks 
Sufficient Data to Inform Its Oversight: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: List of Colleges and Universities GAO Interviewed: 

Appendix III: Comments from the Department of Education: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Percentage of All Title IV Degree-Granting Postsecondary 
Schools Offering Degree or Certificate Programs Totally through 
Distance Education in Academic Year 2006-2007: 

Figures: 

Figure 1: Illustration of Synchronous and Asynchronous Learning 
Methods: 

Figure 2: Percentage of 2-and 4-Year Postsecondary Schools Offering 
Distance Education, by Sector: 

Figure 3: Percentage of Minority-Serving Institutions Offering Distance 
Education: 

Figure 4: Percentage of Postsecondary Schools Offering Distance 
Education, by School Size, 2009-2010: 

Figure 5: Percentage of Students Enrolled in Distance Education, by 
Sector: 

Figure 6: Average Age of Undergraduate and Graduate Students, by 
Distance Education Enrollment Status: 

Figure 7: Percentage of Undergraduate and Graduate Students with Family 
Obligations, by Distance Education Enrollment Status: 

Figure 8: Percentage of Students in Each Race and Ethnicity Group Who 
Participate in Distance Education: 

Figure 9: IPEDS Changes Related to Distance Education: 

Abbreviations: 

CHEA: Council for Higher Education Accreditation: 

DOD: Department of Defense: 

Education Department of Education: 

FSA: Office of Federal Student Aid: 

HEA: Higher Education Act: 

HEOA: Higher Education Opportunity Act: 

IPEDS: Integrated Postsecondary Education Data System: 

IPM: Integrated Partner Management: 

NACIQI: National Advisory Committee on Institutional Quality and 
Integrity: 

NCES: National Center for Education Statistics: 

NPSAS: National Postsecondary Student Aid Study: 

OIG: Office of the Inspector General: 

VA: Department of Veterans Affairs: 

[End of section] 

November 17, 2011: 

The Honorable George Miller:
Ranking Member:
Committee on Education and the Workforce:
House of Representatives: 

The Honorable Ruben Hinojosa:
Ranking Member:
Subcommittee on Higher Education and Workforce Training:
Committee on Education and the Workforce:
House of Representatives: 

As the largest provider of financial aid for postsecondary education, 
with about $134 billion provided to students during fiscal year 2010 
under Title IV of the Higher Education Act of 1965, as amended 
(HEA),[Footnote 1] the U.S. Department of Education (Education) has a 
considerable interest in distance education[Footnote 2]--education that 
uses technology to provide instruction to students who are separated 
from the instructor. Students participating in distance education are 
eligible for federal financial aid in the same way as students taking 
traditional courses. This aid is available through Education in the 
form of grants, loans, and work study wages. While distance education 
has extended the opportunity to continue higher education learning and 
complete degrees to many students, including nontraditional students 
with work and family obligations as well as military personnel, its 
rapid growth in popularity presents challenges for ensuring both its 
quality and the oversight of federal funding. Congress has included a 
number of provisions in the HEA, as amended, such as oversight 
requirements for accrediting agencies, in recognition of the increasing 
role of distance education in higher education and to address concerns 
regarding the academic quality of distance education given the rapid 
growth in this area. Education's Office of the Inspector General (OIG) 
has also raised concerns over the past few years about the ability of 
schools to verify student identities and ensure enrolled students are 
engaged in academic activities given the limited or no face-to-face 
contact with distance education students. 

To provide a national perspective on the nature of distance education 
and its current level of oversight, we were asked to describe (1) the 
characteristics of distance education today, (2) the characteristics of 
students participating in distance education, (3) how the quality of 
distance education is being assessed, and (4) how Education monitors 
distance education in its stewardship of federal student aid funds. 

To conduct our work, we reviewed and analyzed relevant federal laws and 
regulations, literature, studies, and program documents, and consulted 
with subject matter experts. We analyzed data from Education's 
Integrated Postsecondary Education Data System (IPEDS) and the National 
Postsecondary Student Aid Study (NPSAS) databases to determine the 
school and student characteristics involved in distance education. We 
also reviewed information from a 2008 report by Education's National 
Center for Education Statistics (NCES) and a 2010 industry report to 
obtain a national perspective on distance education practices and 
offerings at postsecondary schools. We conducted site visits to 
Florida, Minnesota, and Puerto Rico to visit schools and interview 
state agency officials. We selected these sites based on various 
factors, including the level of state data collected and an industry 
summary of states' policies for approving distance education. We 
interviewed officials from higher education organizations, accrediting 
agencies (three regional, two national, and one specialized), and 
Education to determine their role in overseeing the delivery of 
distance education. Finally, we interviewed school officials from a 
nongeneralizable sample of 20 postsecondary schools to obtain more 
information on current practices in and the specific types of programs 
and coursework being offered through distance education. Our criteria 
for school selection included total enrollment, change in enrollment 
over time, school sector (public, private nonprofit, and private for-
profit), and geographic diversity, among other factors. For more 
information on our scope and methodology, see appendix I. 

We conducted this performance audit from November 2010 to November 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Background: 

Distance education is not a new concept, but in recent years, it has 
assumed markedly new forms and greater prominence. In the past, 
distance education generally took the form of correspondence courses--
home study courses completed by mail. Distance education today can take 
many forms and is defined by federal law and regulation as education 
that uses one or more technologies (such as the Internet or audio 
conferencing) to deliver instruction to students who are separated from 
the instructor and to support regular and substantive interaction 
between the students and the instructor.[Footnote 3] Instruction 
provided through the Internet--or online--may be synchronous 
(simultaneous or "real time") or asynchronous, whereby students and the 
instructor need not be present and available at the same time (see fig. 
1). 

Figure 1: Illustration of Synchronous and Asynchronous Learning 
Methods: 

[See PDF for image: illustration] 

Students do their work at home on their own schedule: 

Students: 

Log into class website: 

Complete online quizzes/tests: 

Interact with instructor and other students using e-mail messages and 
posts on the classes web board: 

Interact with instructor and other students using E-mail messages: 

Instructors conduct classes asynchronously by using learning management 
systems that do not require that all parties be available at the same 
time: 

Instructor: 

Post course materials online: 

Review students' work: 

Post messages for class: 

Respond to students' questions: 

Web conference: 

Web conferencing and chat software can be used for real-time, 
synchronous communication between instructor and students: 

Source: GAO representation of synchronous and asynchronous instruction. 

[End of figure] 

Oversight: 

In general, for their students to be eligible for federal student aid 
funds under Title IV programs, schools must be legally authorized by a 
state, accredited by an agency recognized by Education, and be found 
eligible and certified by Education.[Footnote 4] State governments, 
accrediting agencies, and Education form the program integrity triad 
established by Title IV of the HEA to oversee postsecondary 
education.[Footnote 5] The state authorization role is primarily one of 
providing consumer protection through the state licensing process, 
while the accrediting agencies are intended to function as a quality 
assurance mechanism. In certifying a school for participation,[Footnote 
6] Education is responsible for determining the financial 
responsibility and administrative capability of schools and is also 
responsible for monitoring to ensure compliance with Title IV 
requirements. 

Accrediting agencies, private educational associations set up to review 
the qualifications of member schools, are the primary overseers of 
schools' academic quality. Accreditation is a peer review process that 
evaluates a school against the accrediting agency's established 
standards. An institutional accrediting agency assesses a school in its 
entirety, including resources, admissions requirements, services 
offered, and the quality of its degree programs, while a programmatic 
accrediting agency reviews specific programs or single-purpose schools. 
A school's accreditation is re-evaluated every 3 to 10 years, depending 
on the accrediting agency. If a school makes a substantive change to 
its educational programs or method of delivery from those that were 
offered when the agency last evaluated the school, the agency must 
ensure the change continues to meet standards.[Footnote 7] Schools may 
lose accreditation if their accrediting agency determines that they no 
longer meet the established standards. While Education does not have 
the authority to dictate the specifics of an agency's standards, the 
department recognizes accrediting agencies by reviewing and assessing 
their standards in various areas required by statute, such as student 
achievement, curricula, and student support services.[Footnote 8] 

Education's Office of Federal Student Aid (FSA) is responsible for 
monitoring the over 6,000 postsecondary schools participating in Title 
IV programs to ensure their compliance with applicable statutory and 
regulatory provisions and to ensure that only eligible students receive 
federal student aid. The postsecondary school types include the 
following: 

* Public schools--schools operated and funded by state or local 
governments, including state universities and community colleges. 

* Private nonprofit schools--schools owned and operated by nonprofit 
organizations whose net earnings do not benefit any shareholder or 
individual. 

* For-profit schools--schools that are privately owned or owned by a 
publicly traded company and whose net earnings can benefit a 
shareholder or individual. 

Education fulfills its school monitoring responsibilities through four 
main activities. First, it determines the initial eligibility of 
schools to participate in the federal student aid programs, as well as 
recertifies that eligibility periodically. Second, as part of ensuring 
compliance, FSA staff conduct program reviews of a select number of 
schools each year where they examine school records, interview school 
staff and students, and review relevant student information, among 
other things. FSA issues reports on these reviews, which include 
information on areas where a school was found to be in violation of the 
Title IV requirements. Third, schools are required to employ 
independent auditors to conduct annual compliance reviews and financial 
audits, which are then submitted to Education. Finally, Education's OIG 
conducts its own audits and investigations of schools to identify and 
combat fraud, waste, and abuse and makes recommendations to the 
department. Education may assess liabilities and/or impose fines or 
other sanctions on schools found in violation of Title IV requirements. 

Brief History of Statutory Provisions Related to Distance Education: 

Over the past two decades, Congress has made several changes to the 
Higher Education Act of 1965 that have affected schools' offering, and 
accrediting agencies review, of distance education. To combat cases of 
fraud and abuse at postsecondary schools that primarily delivered 
distance education though correspondence courses, Congress stipulated 
in 1992 that schools were not eligible to participate in federal 
student aid programs if more than 50 percent of their courses were 
offered by correspondence or if more than 50 percent of their students 
were enrolled in correspondence courses. Furthermore, students enrolled 
in telecommunications courses were considered enrolled in a 
correspondence course if the sum of the telecommunications and 
correspondence courses equaled or exceeded 50 percent of the total 
courses offered at the school.[Footnote 9] In 2006, Congress excluded 
telecommunication courses from the first two rules and eliminated the 
requirement that telecommunication courses be considered correspondence 
courses if the sum of both exceeded 50 percent of the total courses 
offered, allowing schools to expand distance education offerings while 
maintaining their eligibility to participate in Title IV 
programs.[Footnote 10],[Footnote 11] 

While Congress has required that accrediting agencies apply and enforce 
standards with regard to distance education offered by schools, 
including that such reviews be included in their scope of accreditation 
since 1998,[Footnote 12] it added additional requirements in 2008 
through the Higher Education Opportunity Act (HEOA).[Footnote 13] 
Although not required to have separate evaluation standards, 
accrediting agencies that have or are seeking to include distance 
education in their scope of review must demonstrate to Education that 
they effectively address the quality of a school's distance education 
program in the same areas they are required to evaluate a school's 
other educational offerings.[Footnote 14] The agencies must require 
schools offering distance education to have processes to establish that 
the student who registers in a distance education course or program is 
the same student who participates in the program.[Footnote 15] 
Additionally, agencies must ensure that accreditation team members 
whose responsibilities include evaluating distance education are well 
trained and knowledgeable with regard to distance education.[Footnote 
16] Finally, all accrediting agencies are required to monitor the 
growth of programs at institutions that are experiencing significant 
enrollment growth.[Footnote 17],[Footnote 18] 

Distance Education Has Become Common in All Sectors and Is Offered 
through a Range of Programs and Courses: 

Online Distance Education Has Grown Dramatically and Is Offered in a 
Variety of Ways: 

While distance education can use various technologies, it has grown 
most rapidly online with the use of the Internet to support interaction 
among users. With the emergence of the Internet and expansion of 
Internet-based communication technologies, distance education today is 
a common phenomenon and widely used throughout higher education. 
Moreover, the term "distance education" no longer connotes only 
instruction separated by physical distance, since many distance 
education courses--specifically online courses--are offered to students 
living on campus as well as away from a campus and across state lines. 
School offerings in online learning range from individual classes to 
complete degree programs. Individual courses as well as degree programs 
may also be a mix of face-to-face and online instruction--often 
referred to as "hybrid" or "blended" instruction. Furthermore, an 
online class may be synchronous (simultaneous, real-time instruction), 
or asynchronous, where students and the instructor are not present and 
available at the same time. 

According to a 2008 study on distance education conducted by Education, 
postsecondary schools of all types offer a variety of distance 
education courses.[Footnote 19] Specifically, for the 2006-2007 school 
year, 61 percent of 2-year and 4-year schools reported offering online 
courses, 35 percent reported hybrid/blended courses, and 26 percent 
reported other types of distance courses. The study also suggests that 
the majority of schools offering distance education used asynchronous 
Internet technologies. Specifically, 92 percent of the degree-granting 
postsecondary institutions offering distance education in 2006-2007 
reported using asynchronous Internet technologies to a moderate or 
large extent, compared with 31 percent of schools that reported using 
synchronous technologies to a moderate or large extent. In our 
interviews at the schools we selected, officials said that online, 
asynchronous instruction was also their predominate method for 
providing distance education and that this type of instruction meets 
students' need for flexible schedules. For example, over half of the 
school officials we interviewed noted that many students taking classes 
online are working adults or active duty military service members who 
would otherwise be unable to continue or complete their studies. 

The use of distance education, particularly online learning, has grown 
dramatically in recent years. According to a 2010 industry survey, 
online enrollment in degree-granting postsecondary schools has 
continued to grow at rates far in excess of the growth for total 
enrollment in higher education.[Footnote 20] Survey results indicate 
that over 5.6 million students were taking at least one online course 
during the fall 2009 term--an increase of nearly 1 million students 
over the number reported the previous year and an increase of 21 
percent, as compared with the less than 2 percent growth in the overall 
higher education student population. The survey also suggests that 
nearly 30 percent of higher education students were taking at least one 
course online. 

Such remarkable growth may be attributed to institutional efforts to 
expand access to more students, alleviate constraints on campus 
capacity, and the desire to capitalize on emerging market opportunities 
and compete with other schools. According to Education's 2008 study on 
distance education, which includes online and other forms of distance 
education, the top four factors affecting postsecondary schools' 
decisions regarding distance education offerings are (1) meeting 
student demand for flexible schedules; (2) providing access to college 
for students who otherwise would not have access due to geographic, 
family, or work-related reasons; (3) making more courses available; and 
(4) seeking to increase student enrollment. Several of these factors, 
such as providing access to more students, were also cited by school 
officials we interviewed. For example, one school we visited had 
increased access to education by establishing over 20 "cyber-centers," 
including one on a National Guard base and another in a shopping mall 
where students can access computers with Internet capabilities and 
participate in online courses as well as complete assignments and take 
exams. Additionally, officials at two of the schools we interviewed 
noted that on-campus students were registering for online classes, 
instead of face-to-face classes that were otherwise full or scheduled 
for times of day that conflicted with their personal schedules. 
Furthermore, one school we interviewed provided flexibility to its 
students by allowing them to begin and complete courses at their own 
pace.[Footnote 21] 

While cost savings might be a factor, none of the school officials we 
spoke with cited cost savings as the primary reason for providing 
online distance education courses and programs. Moreover, they said 
students taking distance education courses, including online courses, 
are generally charged the same tuition and fees as students taking face-
to-face courses.[Footnote 22] These officials cited various costs 
associated with developing and expanding online distance education 
offerings, such as the purchase of hardware and software (which 
includes a learning management system), course development, faculty 
training and salaries, and the provision of student support services. 
They also said online instruction is not necessarily less expensive to 
provide, in part, because schools have to provide similar support 
services to both online students and classroom students--such as 
tutoring, library access, and (virtual) faculty office hours. For 
example, officials at three schools mentioned one of the major expenses 
associated with online distance education is providing off-hours 
library access or tutoring. Also, almost all the officials said it is 
often difficult to isolate the costs of online courses from the costs 
of providing traditional courses. Professors generally teach both 
online and face-to-face course sections, and the infrastructure 
developed for online distance education, such as the online learning 
management systems, can also be used by students and instructors 
participating in face-to-face instruction. 

A Wide Variety of Schools Provide a Range of Distance Education Courses 
and Programs: 

Schools of all types reported offering distance education, according to 
data collected by Education through its annual IPEDS survey.[Footnote 
23] Specifically, during the 2009-2010 school year, 46 percent of all 
Title IV eligible schools reported that they offered distance education 
opportunities to their students. Figure 2 shows the variation among 
these schools by sector and program length. 

Figure 2: Percentage of 2-and 4-Year Postsecondary Schools Offering 
Distance Education, by Sector: 

[Refer to PDF for image: vertical bar graph] 

Public: 4-year schools: 88; 
Public: 2-year schools: 93; 
Public: Schools less than 2 years: 17. 

Private nonprofit: 4-year schools: 51; 
Private nonprofit: 2-year schools: 22; 
Private nonprofit: Schools less than 2 years: 4. 

Private for-profit: 4-year schools: 78; 
Private for-profit: 2-year schools: 19; 
Private for-profit: Schools less than 2 years: 2. 

Sources: Education and GAO analysis of IPEDS for the 2009-2010 school 
year. 

[End of figure] 

As shown in figure 2, public schools, both 2-and 4-year, were more 
likely to offer distance education opportunities than private nonprofit 
or for-profit schools. Among public schools, distance education was 
more likely to be offered at 2-year schools rather than 4-year schools. 
One school official we spoke with attributed this likelihood to the 
increased number of students at 2-year schools, given the weak economy 
and limited capacity at 4-year public schools. 

With regard to minority-serving institutions and institutions with 
specific high minority concentrations,[Footnote 24] IPEDS data indicate 
that these institutions are as likely or more likely to offer some 
distance education than all schools combined, with the exception of 
Hispanic-serving institutions. For the 2009-2010 school year, more than 
60 percent of Historically Black Colleges and Universities and Tribal 
Colleges and Universities offered distance education opportunities to 
their students, compared with about 46 percent of institutions overall. 
Furthermore, 49 percent of Asian/Pacific Islander/Native Hawaiian-
serving institutions offered distance education to their students. 
Among Hispanic-serving institutions, just over 30 percent of these 
schools were offering distance education (see fig. 3).[Footnote 25] 

Figure 3: Percentage of Minority-Serving Institutions Offering Distance 
Education: 

[Refer to PDF for image: horizontal bar graph] 

Minority Serving institutions: All institutions: 46; 
Total number of schools: 7,024. 

Minority Serving institutions: Historically Black Colleges and 
Universities: 63; 
Total number of schools: 98. 

Minority Serving institutions: Tribal Colleges and Universities: 66; 
Total number of schools: 32. 

Minority Serving institutions: Hispanic-serving institutions: 33; 
Total number of schools: 1,091. 

Minority Serving institutions: Asian/Pacific Islander/Native Hawaiian 
serving institutions: 49; 
Total number of schools: 554. 

Sources: Education and GAO analysis of IPEDS for the 2009-2010 school 
year. 

[End of figure] 

With regard to the size of schools that offer some distance education, 
the IPEDS data suggest that larger schools--as defined by enrollment--
are more likely to offer distance education opportunities than smaller 
schools. Specifically, 23 percent of schools with fewer than 1,000 
students offered distance education, while 96 percent of larger 
schools--those with 20,000 or more students--did so (see fig. 4). 

Figure 4: Percentage of Postsecondary Schools Offering Distance 
Education, by School Size, 2009-2010: 

[Refer to PDF for image: horizontal bar graph] 

Size of schools: 20,000 and more; 
Percentage that offered distance education: 96; 
Total number of schools: 227. 

Size of schools: 10,000-19,999; 
Percentage that offered distance education: 95; 
Total number of schools: 359. 

Size of schools: 5,000-9,999; 
Percentage that offered distance education: 92; 
Total number of schools: 543. 

Size of schools: 1,000-4,999; 
Percentage that offered distance education: 69; 
Total number of schools: 1,749. 

Size of schools: Under 1,000; 
Percentage that offered distance education: 23; 
Total number of schools: 4,113. 

Source: Education and GAO analysis of IPEDS for the 2009-2010 school 
year. 

[End of figure] 

The 2008 distance education study by Education provided additional 
insights on the extent and nature of distance education offerings by 
school type, sector, and size. In terms of full degree and certificate 
programs, the study indicated that in the 2006-2007 academic year, 
about a third of all degree-granting schools offered entire degree 
programs or certificate programs through distance education. 
Additionally, public schools were more likely to offer a degree or 
certificate program entirely through distance education than were 
private schools. Larger schools were also more likely to offer a degree 
or certificate program entirely through distance education than smaller 
schools (see table 1). 

Table 1: Percentage of All Title IV Degree-Granting Postsecondary 
Schools Offering Degree or Certificate Programs Totally through 
Distance Education in Academic Year 2006-2007: 

School type and size: All schools; 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 32. 

School type and size: Public, 2-year; 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 45. 

School type: Public, 4-year (undergraduate and graduate programs); 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 58. 

School type: Private for-profit, 2 year; 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 7. 

School type: Private for-profit, 4-year (undergraduate and graduate 
programs); 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 27. 

School type: Private nonprofit, 4-year (undergraduate and graduate 
programs); 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 24. 

Size of school: Less than 3,000; 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 19. 

Size of school: 3,000 to 9,999; 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 49. 

Size of school: 10,000 or more; 
Percentage of schools that offered college-level degree or certificate 
programs through distance education: 67. 

Source: U.S. Department of Education. 

[End of table] 

Students in Distance Education Enroll Mostly in Public Schools and 
Represent a Diverse Population: 

Most Distance Education Students Attend Public Schools and Study a 
Range of Subjects: 

Our analysis of the NPSAS[Footnote 26] data for the 2007-2008 academic 
year showed that of the estimated 5 million[Footnote 27] postsecondary 
students who have taken distance education, participation was most 
common among students attending public schools. These students enrolled 
in a range of academic fields of study. 

Most distance education students enroll at public schools. As might be 
expected, most undergraduate and graduate students taking distance 
education courses or programs were enrolled at public schools, followed 
by private nonprofit and private for-profit schools (see fig. 5). 

Figure 5: Percentage of Students Enrolled in Distance Education, by 
Sector: 

[Refer to PDF for image: horizontal bar graph] 

School type: Public; 
Percentage of student participation: Undergraduates: 80; 
Estimated number of students: Undergraduate: 15,894,000; 

School type: Public; 
Percentage of student participation: Graduates: 53; 
Estimated number of students: Graduates: 1,631,000. 

School type: Private nonprofit; 
Percentage of student participation: Undergraduates: 10; 
Estimated number of students: Undergraduate: 3,039,000; 

School type: Private nonprofit; 
Percentage of student participation: Graduates: 35; 
Estimated number of students: Graduates: 1,290,000. 

School type: Private for-profit; 
Percentage of student participation: Undergraduates: 10; 
Estimated number of students: Undergraduate: 1,995,000; 

School type: Private for-profit; 
Percentage of student participation: Graduates: 13; 
Estimated number of students: Graduates: 253,000. 

Source: GAO analysis of NPSAS for the 2007-2008 academic year. 

[End of figure] 

Distance education students enroll in a variety of fields of study. 
Both undergraduate and graduate students taking distance education 
courses or programs had higher rates of enrollment in the fields of 
business and health. Undergraduates taking distance education courses 
and programs also often majored in the humanities (liberal arts), while 
graduate students often studied education. 

While Students in Distance Education Tend to Be Older and Female, and 
Have Family and Work Obligations, They Are Also a Diverse Population: 

According to our analysis of 2007-2008 NPSAS data, distance education 
students varied somewhat from students who did not enroll in distance 
education in that they tended to be somewhat older and female, and have 
family and work obligations.[Footnote 28] Moreover, students who are 
participating in distance education represent a diverse population that 
includes students of all races, current and former members of the 
military, and students with disabilities.[Footnote 29] Some of these 
characteristics are consistent with what we reported in our 2002 
testimony on distance education[Footnote 30] and also were corroborated 
in our recent interviews with selected schools for this report. 

Distance education students tend to be older. As figure 6 shows, 
undergraduate and graduate students who took distance education courses 
or programs were about 3 years older, on average, when compared with 
students who did not take any distance education courses. 

Figure 6: Average Age of Undergraduate and Graduate Students, by 
Distance Education Enrollment Status: 

[Refer to PDF for image: vertical bar graph] 

Undergraduate students; 
Students: Took no distance education courses: Average age: 25; 
Students: Took distance education course or program: Average age: 28. 

Graduate students; 
Students: Took no distance education courses: Average age: 32; 
Students: Took distance education course or program: Average age: 35. 

Source: GAO analysis of NPSAS for the 2007-2008 academic year. 

[End of figure] 

Distance education students are more often female. Women represented 
about 61 percent of undergraduate students who took distance education 
courses or programs, compared with about 56 percent of undergraduates 
who took no distance education, and about 57 percent of undergraduates 
overall. For graduate students, the percentage of students taking 
distance education courses or programs who were female was about 65 
percent, which was higher than those who took no distance education (59 
percent) and the overall percentage of graduate students who were 
female (61 percent). 

Distance education students more often have family obligations. Figure 
7 shows that undergraduate and graduate students who took distance 
education courses or programs were more often married and had 
dependents than those taking no distance education courses. 

Figure 7: Percentage of Undergraduate and Graduate Students with Family 
Obligations, by Distance Education Enrollment Status: 

[Refer to PDF for image: vertical bar graph] 

Students who were married: Undergraduate students: Took no distance 
education courses: Percentage: 15; 
Students who were married: Undergraduate students: Took distance 
education course or program: Percentage: 28. 

Students who were married: Graduate students: Took no distance 
education courses: Percentage: 39; 
Students who were married: Graduate students: Took distance education 
course or program: Percentage: 52. 

Students who had dependents: Undergraduate students: Took no distance 
education courses: Percentage: 23; 
Students who had dependents: Undergraduate students: Took distance 
education course or program: Percentage: 36. 

Students who had dependents: Graduate students: Took no distance 
education courses: Percentage: 31; 
Students who had dependents: Graduate students: Took distance education 
course or program: Percentage: 48. 

Source: GAO analysis of NPSAS for the 2007-2008 academic year. 

[End of figure] 

Distance education students more often work full time. A higher 
percentage of students who took distance education courses or programs 
worked full time when compared with students who did not take any 
distance education courses. This difference was greatest among graduate 
students--about 74 percent of the students who took distance education 
courses or programs worked full time compared with 57 percent of 
students who did not take any distance education courses.[Footnote 31] 
For undergraduates, the figures were 45 percent and 31 percent, 
respectively.[Footnote 32] 

Students of all races and ethnicities participate in distance education 
to some extent.[Footnote 33] Postsecondary students of various races 
and ethnicities participated in distance education (see fig. 
8).[Footnote 34] 

Figure 8: Percentage of Students in Each Race and Ethnicity Group Who 
Participate in Distance Education: 

[Refer to PDF for image: horizontal bar graph] 

Students of various races: All students; 
Percentage of student participation: 21; 
Estimated total number of students: 24,384,000. 

Students of various races: White; 
Percentage of student participation: 22; 
Estimated total number of students: 15,228,000. 

Students of various races: Black or African American; 
Percentage of student participation: 21; 
Estimated total number of students: 3,330,000. 

Students of various races: Hispanic of Latino; 
Percentage of student participation: 17; 
Estimated total number of students: 3,326,000. 

Students of various races: Asian; 
Percentage of student participation: 17; 
Estimated total number of students: 1,610,000. 

Students of various races: American Indian or Alaska Native; 
Percentage of student participation: 22; 
Estimated total number of students: 186,000. 

Students of various races: Native Hawaiian or Pacific Islander; 
Percentage of student participation: 18; 
Estimated total number of students: 160,000. 

Students of various races: Other; 
Percentage of student participation: 12; 
Estimated total number of students: 68,000. 

Students of various races: More than one race; 
Percentage of student participation: 21; 
Estimated total number of students: 566,000. 

Source: GAO analysis of the 2007-2008 NPSAS. 

[End of figure] 

Current and former members of the military enrolled in postsecondary 
education participate in distance education. Forty-five percent of 
active duty service members, 29 percent of reservists, and 30 percent 
of veterans enrolled in postsecondary education took distance education 
courses or programs.[Footnote 35] In addition, of those enrolled in 
postsecondary education, 42 percent of active duty service members with 
a disability and 29 percent of veterans with a disability took distance 
education courses or programs.[Footnote 36] Taken together, active duty 
service members, reservists, and veterans represented about 7 percent 
of all students taking distance education courses and programs, 
compared with 4 percent of students who took no distance education. 

Students with disabilities participate in distance education. Twenty-
one percent of all students with disabilities, including members of the 
military and civilians, enrolled in distance education courses or 
programs.[Footnote 37] Further, 25 percent of students with 
disabilities affecting their mobility took distance education courses 
or programs. Students with disabilities represented 10 percent of all 
students taking distance education courses and programs, while students 
with mobility disabilities represented about 3 percent.[Footnote 38] 

Many of these student characteristics were also noted by school 
officials we interviewed. These school officials reported that they 
collect data such as age, gender, and race and ethnicity of their 
students. The demographic data provided from schools generally showed 
similar student characteristics as that suggested by the 2007-2008 
NPSAS data--that distance education students tend to be older and 
female, and have work and family obligations. Officials of at least 
three of the schools we selected indicated that many of their students 
taking classes online are veterans or students serving in the military. 
While at least three schools reported tracking students who identified 
themselves as having disabilities, at the time of our interviews, none 
of these schools indicated that they had determined how many of these 
students were taking online distance education classes. Officials at 
one of these schools, however, conducted some analysis after our 
interview and reported that about 3 percent of their students enrolled 
in the past year had documented disabilities. These students took, on 
average, 15 percent of their classes online.[Footnote 39] 

While most of the schools where we conducted interviews collected 
demographic data on their students, including those taking courses 
online, less than half of these schools have compared the demographics 
of students taking completely online courses with those taking face-to-
face courses. Officials at five schools mentioned that comparing data 
on students can be difficult, in part, because students can take 
courses or degrees through a mix of instructional modalities--including 
completely online, hybrid/blended (mix of online and face-to-face), and 
completely face-to-face. For example, officials from one private 
nonprofit 4-year school that offers completely online as well as 
blended courses and degrees said that it is difficult to collect 
comparison data because the school's administrative records do not 
differentiate online students from those who enroll in both online and 
campus-based courses. 

Accreditors and Schools Assess the Academic Quality of Distance 
Education in Several Ways, but Accreditors Reported Some Oversight 
Challenges: 

Accrediting Agencies Examine the Quality of Distance Education in 
Various Ways but Reported Some Challenges: 

Accreditors we interviewed have various procedures to examine schools' 
distance education programs, but some accreditors reported they face 
challenges.[Footnote 40] Federal law and regulations require 
accrediting agencies to have standards that address student 
achievement, curricula, faculty, and student support services, among 
other areas. In addition, accreditors must ensure that schools have a 
process in place to verify registered students are doing their own work 
by using methods such as secure logins, passwords, proctored 
examinations, or other technologies. However, accrediting agencies are 
not required to have separate standards for distance 
education.[Footnote 41] As such, accreditors we spoke with who accredit 
both distance education and face-to-face programs use the same 
standards for both, although they differed in the practices they used 
to examine schools offering distance education. 

The accreditors we spoke with conduct reviews of schools' distance 
education programs according to the accreditors' own standards. For 
example, to address the effectiveness of a program, accreditors may 
review such measures as student retention rates, completion/graduation 
rates, student satisfaction, placement rates (if applicable), and 
various measures of student learning. The three regional accreditors we 
spoke with give schools the responsibility for determining the best way 
to assess student learning for both face-to-face and distance education 
programs. However, both national accrediting agencies and the 
specialized accreditor we spoke with have specific quantitative 
thresholds as minimum standards on various outcomes. For example, one 
national accreditor requires that their member schools meet specific 
thresholds for student retention and placement rates. Officials at this 
agency said they could sanction schools whose programs fall below these 
standards. The other national accreditor we spoke with also requires 
its schools to meet thresholds established for outcomes such as course 
completion rates, program graduation rates, student satisfaction rates, 
and student learning (as measured by professional licensing exams such 
as those for physical therapists and lawyers). One regional accreditor 
said it was exploring including standardized learning outcomes in its 
accreditation standards.[Footnote 42] 

As part of their periodic site visits to schools to assess the quality 
of academic programs, accreditors have to adapt their approach when 
reviewing schools with distance education. Accreditors are required to 
employ staff who are well-trained and knowledgeable about distance 
education, for example, when performing on-site reviews of schools 
providing distance education.[Footnote 43] Officials at all six 
accrediting agencies we spoke with said they include such experts on 
their on-site review teams. At one regional accreditor we interviewed, 
distance education experts are tasked with specifically reviewing the 
quality of a school's distance education learning infrastructure, as 
well as the educational effectiveness of its programs, and receive 
specific training to do so. To review schools' student supports, 
faculty supports, and educational effectiveness, officials at another 
regional accreditor told us their distance education experts may use 
video teleconferences or e-mails to communicate with administrative 
staff, faculty, and students not located on campus. These experts also 
remotely observe interactions between students and faculty in online 
classes. 

In addition to the periodic on-site accreditation reviews to reassess a 
school's accreditation status that are required by statute,[Footnote 
44] accreditors are to be notified if schools make substantive changes 
to academic programs or their schools.[Footnote 45] The main purpose of 
this substantive change policy is to ensure that when schools make 
changes, they are maintaining the same level of quality they had when 
last reviewed. While there are a number of circumstances that can 
trigger the substantive change requirement, the one most applicable to 
distance education is the addition of courses or programs that 
represent a significant departure from the existing offerings of 
educational programs, including method of delivery, from those that 
were offered when the accreditor last evaluated the school. A shift to 
distance education courses that constitute more than 50 percent of a 
program's offerings was the substantive change threshold used by four 
of the six accrediting agencies we interviewed. Officials at one 
regional accrediting agency reported that, in calendar year 2010, the 
agency turned down 34 percent of initial substantive change requests 
for new distance education programs because of weak student learning 
assessments or inadequately trained faculty, among other reasons. 
However, they said this figure has since come down to about 16 percent 
because schools have had more training on how to develop a substantive 
change proposal. 

To ensure academic integrity, the six accrediting agencies we 
interviewed require schools to provide evidence that they verify 
registered students are doing their own work. For example, officials at 
one regional accreditor we spoke with said they require schools to use 
a student identification number and password as the minimum for 
verifying student identity. This accreditor said most institutions also 
verify student identity through student interaction during the course. 
In addition, one national accreditor we spoke with said some schools 
design tests that require a login and password, and may also feature 
pop-up questions during tests, prompting students to enter verification 
information such as their address or mother's maiden name. 

While the accreditors we interviewed have a range of activities to 
assess the quality of distance education, a few accrediting agency 
officials and industry experts we spoke with also expressed some 
concerns and reported challenges involved in assessing the quality of 
distance education. These challenges were mostly related to 
accreditors' capacity to keep pace with substantive changes and conduct 
follow-up quality reviews with schools. Officials at one regional and 
one national accrediting agency said they have had some difficulty 
keeping up with the high number of substantive change applications for 
new online programs. Officials representing the national accreditor 
said these applications have increased by about 30 percent and that the 
officials have had to double the number of evaluators on staff over the 
last 5 years. According to officials with the regional accreditor, they 
have increased the number of follow-up reviews to ensure that schools 
address concerns about meeting quality standards identified during the 
initial site visits. These officials reported that they withdrew one 
school's accreditation for failure to demonstrate that its distance 
education programs met the same standards as its face-to-face programs, 
with respect to curriculum, resources, support, and student learning 
outcomes. Industry experts also acknowledged that some accreditors have 
limited resources and have had problems training their peer reviewers 
in distance education. 

Schools Use a Range of Course Design Principles and Student Performance 
Assessments to Hold Distance Education to the Same Quality Standards as 
Traditional Courses: 

To assure that their distance education programs are accredited by 
federally recognized accreditors and that their students qualify for 
Title IV funding, officials we interviewed at 20 selected schools 
reported that they generally apply certain course design principles and 
use student performance assessments to assess the quality of the 
courses that make up these programs. The accreditors we spoke with 
require schools to have standards that address the quality of degree 
programs with respect to such things as student achievement, which 
could include such measures as course completion, licensing exams, and 
job placement rates, as well as student support services. A majority of 
school officials reported that they assess their distance education 
courses by the same standards they use for their traditional courses. 

Officials at most of the schools we spoke with said they used 
instructional teams to design their distance education courses 
according to the schools' standards. These teams varied in their 
composition and activities.[Footnote 46] Some teams include specialized 
staff who work with faculty to translate traditional face-to-face 
courses to the online environment. For example, one school we visited 
in Florida has a 20-member instructional design team that includes 
instructional designers, graphic artists, multimedia technicians, and 
quality control coordinators. Officials at this school said the design 
team considers which instructional methods are most appropriate for the 
material delivered in each online course. For example, a psychology 
course may use mostly text-based storytelling, while an anthropology 
class may rely more heavily on video clips. Officials at an online 
school we spoke with stressed the need to replace face-to-face course 
instructors' body language and tone of voice cues with appropriate text 
and video media. Besides assisting professors with designing online 
courses, school officials said instructional design teams also train 
professors in the pedagogical differences of teaching online and on the 
online technology used by the school. 

Officials at over half of the 20 schools we interviewed also reported 
that, to ensure quality in the design of their courses, they had used 
standards and best practices, some of which were developed by distance 
education industry experts. For example, 5 schools subscribe to Quality 
Matters, a nonprofit organization that lays out principles for 
designing quality online and blended courses. This organization sets 
specific standards for learning objectives, technology, faculty-student 
interaction, student supports, and assessment that online courses must 
meet in order to receive Quality Matters certification. 

In addition, school officials reported that their schools collect 
outcome data to help them assess the quality of courses. The types of 
learning outcomes that the schools reported tracking include end-of-
course grades, course completion rates, and results of national 
professional licensing assessments. Officials at most schools we spoke 
with said they also used outcome data to make improvements to their 
courses. Officials at two schools told us they employ staff to analyze 
these data and make recommendations for course updates. For example, 
officials at one fully online school we spoke with noticed their 
students were performing below the national average on a section of a 
third-party end-of-course criminal justice test. The officials used the 
results of this test to strengthen the related material. According to 
these officials, their criminal justice students' performance improved 
on that section of the exam subsequent to their course improvements. In 
addition to using outcome data to improve their courses, one school we 
spoke with in Florida had collected these types of data on their online 
and hybrid courses over a period of 15 years to determine which factors 
most influenced student success. 

To meet accreditors' requirement to verify the identities of students 
enrolled in their distance education courses or programs, officials at 
most of the schools reported using various methods. For example, most 
of the school officials we interviewed said they issue students a 
secure login and password and some also use other methods, such as 
proctored exams. Officials at one school said they are also starting to 
use audiovisual software that works as a web cam to verify the student 
taking an exam is the one enrolled in the course and to ensure the 
student is not receiving assistance. In addition to technological 
safeguards, officials from one school said the interaction between 
students and faculty is key to ensuring students are doing their own 
work. They said instructors become familiar with a student's writing or 
communication style through online discussions or the completion of 
assignments, and the instructor recognizes if that style changes. 
Officials at one school said they cannot be completely sure that 
distance education students are doing all of their own work even when 
using these methods; officials also noted that similar challenges exist 
for face-to-face courses. A few schools mentioned taking further steps 
to combat potential fraud in their online programs. Specifically, 
officials at two of the completely online schools we interviewed said 
they conduct reviews of or request further documentation from students 
who register with the same e-mail addresses or telephone 
numbers.[Footnote 47] Officials at one school we spoke with said they 
would like more guidance, either from Education or their institutional 
accrediting agency, on examples of verification and authentication 
systems for student identity to improve the school's monitoring of the 
verification process. 

Education Has Increased Its Monitoring of Distance Education but Lacks 
Sufficient Data to Inform Its Oversight: 

Education's Office of Federal Student Aid (FSA) has recently increased 
its monitoring of distance education by updating its program review 
procedures and undertaking a risk analysis project. These efforts are 
in response to the expansion of distance education and the Education 
OIG's identification of distance education as a high-risk area for 
managing student aid dollars.[Footnote 48] To better monitor distance 
education, FSA updated and issued new program review procedures. The 
previous set of FSA's procedures, issued in 2008, did not provide in-
depth guidance for assessing whether a school was approved to offer 
distance education or if there was regular and substantive interaction 
between instructors and students. The new procedures on distance 
education provide staff with expanded guidance for assessing a school's 
compliance with these requirements. FSA officials said staff have been 
trained on the new procedures and, as of June 2011, have been using 
them for program reviews.[Footnote 49] All program reviews will include 
at least routine testing to determine basic program eligibility for 
schools that offer distance education, according to Education 
officials. Schools that offer more than half of any of their programs 
through distance education will also be required to undergo expanded 
testing for regular and substantive interaction. 

Compliance with federal student aid requirements by schools offering 
distance education programs is difficult to assess because many of the 
violations Education identifies through its program reviews are not 
specific to distance education; for those that are, Education does not 
necessarily identify or code the violations as such in its database, 
according to an Education official. For example, violations such as a 
school not appropriately returning Title IV funds when a student 
withdraws are coded in Education's database based on the type of 
violation rather than whether this violation occurred in traditional or 
distance education. Violations specific to distance education that are 
tracked by Education are related to a lack of regular and substantive 
interaction between instructor and students and certain accreditation 
issues, such as an accrediting agency being ineligible because it does 
not have distance education in its scope. Education reported that from 
October 2005 through May 2011, no program reviews or audits identified 
any lack of regular and substantive interaction or distance education 
accreditation violations.[Footnote 50] 

In addition to FSA updating the program review procedures, in 2009, OIG 
and FSA, at the request of the Deputy Undersecretary, initiated a 
project analyzing risk factors for noncompliance with Title IV 
requirements by schools offering distance education. Under this 
project, 27 schools were selected for review based on a set of 
indicators OIG and FSA considered to be high risk for noncompliance, 
such as a large change in the amount of federal student aid a school is 
receiving.[Footnote 51],[Footnote 52] The OIG/FSA group is conducting 
this project in conjunction with others in the department.[Footnote 53] 
FSA officials were not able to estimate a date when all final project 
reports will be issued, but said their last program review was 
conducted in early August 2011. They said the results of the project, 
including its methods for identifying high-risk schools and the 
procedures used, will be evaluated to determine if any changes need to 
be made to FSA's annual program reviews. 

While the objective of the project was to review high-risk distance 
education schools, Education lacked data to adequately identify 
schools' level of risk based on the extent to which they offered 
distance education and the amount of federal student aid they received 
for those programs or courses. For example, to identify high-risk 
schools that may be offering distance education courses and programs, 
one indicator Education relied on was the Department of Defense's 
enrollment information on its military members. Because distance 
education provides the flexibility needed to fit active duty service 
members' duty schedules and location, many military members are 
enrolled in distance education courses and programs.[Footnote 54] 
Therefore, in its risk analysis, Education included schools that had 
200 or more military members receiving tuition assistance from the 
Department of Defense. While Education's IPEDS database can show which 
schools offer distance education, it lacks information on the extent of 
a school's offerings and enrollment levels. Despite using data from 
multiple sources, one of the 27 schools Education originally selected 
for review through the risk analysis did not actually offer distance 
education. As a result, FSA officials said they had to substitute 
another school for the study. While the project is not yet complete, 
officials reported confidence that their study is currently based on an 
appropriate selection of schools.[Footnote 55] Nevertheless, they 
acknowledged that, in selecting their target schools, they lacked 
sufficient data to help them identify the extent to which a school was 
offering distance education as well as the amount of federal dollars 
being spent for distance education at each school, both of which would 
have been significant in evaluating a school's risk. 

The Office of Federal Student Aid has plans to collect more information 
on distance education, but complete information on all schools may not 
be available for several years. Under its new Integrated Partner 
Management (IPM) system, which will consolidate data systems on schools 
receiving Title IV funds, FSA will collect information about how a 
school's programs are offered. Specifically, FSA officials said when 
schools apply for Title IV initial certification or recertification, 
they will be asked to indicate whether a program is predominantly (more 
than 50 percent) delivered via the classroom, distance education, 
correspondence, or independent study. They said the IPM system is 
expected to be implemented in November 2012 and would eventually allow 
them to analyze comprehensive data about a school. For example, they 
will be able to match the extent to which schools offer distance 
education with Title IV violations identified during program reviews. 
However, because schools are generally required to recertify only every 
6 years, officials acknowledged that it could be several years before 
the IPM system will contain information on all schools' distance 
education offerings.[Footnote 56] Therefore, distance education 
information on all schools may not be available through IPM until 2018. 

In the meantime, Education's NCES is expanding its IPEDS survey to 
provide a more in-depth picture of distance education offerings and 
enrollment patterns.[Footnote 57] The plan by NCES to expand the IPEDS 
survey with regard to distance education was the result of a decision 
by its technical review panel to better describe postsecondary 
education offered throughout the nation, allow schools to compare their 
distance education activities with those of their peer schools, and 
provide valuable information to parents and students on available 
college programs. This expanded data collection will be conducted in 
phases. The 2011-2012 survey used the definition of distance education 
as established in 2008 and collected information about whether schools 
offer their programs completely through distance education. Additional 
new distance education questions will be added to the 2012-2013 survey. 
The new survey questions ask for information such as the range of a 
school's offerings in distance education, the number of students 
enrolled either partially or entirely in distance education, and 
whether the students are located in or out of state in relation to the 
school (see fig. 9). An NCES official said the new IPEDS data are 
expected to be available 1 year after the survey closes but may be 
available earlier. For example, early release data collected during the 
2011-2012 survey may be available as early as February 2012 and 
available publicly by November 2012. 

Figure 9: IPEDS Changes Related to Distance Education: 

[Refer to PDF for image] 

IPEDS distance education data fields: 

Old data field: 

What types of special learning opportunities are offered by your 
institution? 

[Check all that apply] 

Distance learning opportunities (e-learning): 

Reserve Officer Training Corps: 

Study abroad: 

Weekend/evening college: 

Teacher Certification: 

None of the above: 

New definitions and data fields: 

Beginning in 2011-2012: 

Distance education: 

Education that uses one or more technologies to deliver instruction to 
students who are separated from the instructor and to support regular 
and substantive interaction between the students and the instructor 
synchronously or asynchronously. Technologies used for instruction may 
include the following: Internet; one-way and two-way transmissions 
through open broadcasts, closed circuit, cable, microwave, broadband 
lines, fiber optics, satellite or wireless communication devices; audio 
conferencing; and video cassette, DVDs, and CD-ROMs, if the cassette, 
DVDs, and CD-ROMs are used in a course in conjunction with the 
technologies listed above. 

Are all the programs at your institution offered completely via 
distance education? 

Yes: 

No: 

Beginning in 2012-2013: 

Please indicate at what level(s) you offer distance education 
opportunities: 

Undergraduate: 

Graduate: 

The school does not offer distance education opportunities: 

What programs are offered exclusively by distance education? 

[Report by classification instructional program code, award level (e.g	
associate's degree, bachelor's degree, etc.), gender, race, and 
ethnicity][A]: 

How many students are: 

Enrolled exclusively in distance education courses: 

Enrolled in some but not all distance education courses: 

Not enrolled in any distance education courses: 

[Report by undergraduate (degree/certificate seeking or 
nondegree/certificate seeking) or graduate status.]: 

Of those students exclusively enrolled in distance education courses, 
report the number that are: 

Located in the state (of the school): 

Located in the U.S., but not in the state (of the school): 

Located in the U.S., but state unknown: 

Located outside the U.S.: 

[Report by undergraduate (degree/certificate seeking or 
nondegree/certificate seeking) or graduate status.]: 

Source: GAO analysis of Education data. 

[A] The classification instructional program code is a coding scheme 
that contains titles and descriptions of instructional programs. 

[End of figure] 

Despite the prospect of more comprehensive data on schools and their 
distance education offerings being collected through IPEDS, FSA does 
not yet have specific plans to use these data for monitoring school 
compliance with federal student aid requirements. According to FSA 
officials, they intend to wait and see what information the survey 
yields before deciding how to make use of it.[Footnote 58] Moreover, 
FSA indicated it was not aware of NCES's efforts to expand the IPEDS 
distance education data collection and, therefore, was not involved in 
the planning and did not provide input during comment periods.[Footnote 
59] According to NCES officials, the NCES technical review panel 
process engages a number of stakeholders and is open to federal 
officials who are interested in participating. 

Conclusions: 

Distance education, specifically online education, has been developing 
for a number of years and has become a part of the mainstream of higher 
education. This delivery mode of instruction has provided some new 
opportunities and access, particularly for nontraditional students and 
working adults who are looking to advance their careers. Moreover, it 
is likely to continue growing, as schools across all sectors and levels 
see it as a critical educational tool in meeting student needs and 
demand. 

The growth in distance education and the sizable federal investment in 
higher education will challenge all segments of the triad responsible 
for the oversight of higher education--the states, accreditation 
agencies, and the federal government--in their capacity to provide 
consumer protection, ensure academic quality, and protect the federal 
investment. In response to this challenge, Education has taken steps to 
increase its oversight by providing its staff with expanded guidance 
for assessing a school's compliance with distance education 
requirements and participating in the OIG/FSA risk project, which 
identified potential risk indicators. However, a key factor in 
Education's ability to properly focus oversight on the areas of 
greatest risk will be the availability and use of pertinent, up-to-date 
data on both the extent to which schools offer distance education and 
the extent to which students use federal aid to attend those programs. 

While FSA's IPM system may eventually be helpful in providing Education 
with the opportunity to monitor distance education with better 
information, the expanded IPEDS data would provide relevant information 
much sooner. However, without a plan on how to use the new IPEDS data 
to identify and monitor high-risk schools, FSA may lose the opportunity 
to strengthen its oversight of distance education in the near term. 
Moreover, if FSA does not coordinate with NCES going forward, it stands 
to lose the opportunity to provide input on any additionally needed 
data that may strengthen oversight and ensure accountability in the 
long term. 

Recommendation for Executive Action: 

To help Education strengthen its oversight of distance education, the 
Secretary of Education should direct FSA to develop a plan on how best 
to use the new IPEDS distance education data and provide input to NCES 
on future IPEDS survey work with regard to distance education. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to officials at Education for their 
review and comment. Education provided comments, which are reproduced 
in appendix III of this report, and technical comments, which we 
incorporated as appropriate. In its comments, Education agreed with our 
recommendation and noted that FSA will update its School Participation 
Team procedures to include consideration of IPEDS data on distance 
education for monitoring schools. Education also stated that FSA will 
provide input to NCES on the design and results of any future IPEDS 
surveys that include distance education. 

We are sending copies of this report to relevant congressional 
committees, the Secretary of Education, and other interested parties. 
In addition, this report will also be available at no charge on GAO's 
website at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made key contributions to 
this report are listed in appendix IV. 

Signed by: 

George A. Scott: 

Director, Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This appendix discusses in detail our methodology for addressing the 
following research objectives: (1) the characteristics of distance 
education today, (2) the characteristics of students participating in 
distance education, (3) how the quality of distance education is being 
assessed, and (4) how Education monitors distance education in its 
stewardship of federal student aid funds. 

To address these research questions, we reviewed relevant federal laws 
and regulations, literature, studies, and reports; interviewed 
officials from Education, representatives from all types of 
postsecondary schools, accreditation agencies, and distance education 
and industry experts; and conducted site visits to Florida, Minnesota, 
and Puerto Rico to interview state agency and school officials. We 
selected these sites based on various factors, including the level of 
state data collected and an industry summary of states' policies for 
approving distance education. We also analyzed data from Education's 
Integrated Postsecondary Education Data System (IPEDS) and the National 
Postsecondary Student Aid Study (NPSAS) databases to determine the 
school and student characteristics involved in distance education. We 
determined that IPEDS and NPSAS data were sufficiently reliable for the 
purposes of this report based on prior testing of the data from these 
systems in 2011.[Footnote 60] The data were tested for accuracy and 
completeness, documentation about the data and systems used to produce 
the data was reviewed, and agency officials were interviewed. 

To determine the current characteristics of distance education, we 
analyzed 2009-2010 data from Education's IPEDS and also from a 2008 
report by Education's National Center for Education Statistics 
(NCES)[Footnote 61] to obtain a national perspective on distance 
education practices and offerings at postsecondary schools. 
Specifically, we analyzed IPEDS data to provide information on the 
size, number, sector, and program length of schools offering distance 
education courses and programs. We used the 2008 distance education 
report to describe how schools are providing distance education to 
students, including the type of technology (Internet, video, audio, 
etc.) and instructional methods (asynchronous and synchronous) used, 
and the various types of degrees, certificates, and courses offered, 
including the percentage of courses offered online. In addition, we 
analyzed the 2010 Sloan Consortium[Footnote 62] report on online 
education to show updated enrollment figures specific to online 
courses.[Footnote 63] We supplemented the nationally representative 
data with information obtained from our interviews with industry 
experts and representatives at a nongeneralizable sample of 
postsecondary schools regarding the range of delivery and instructional 
techniques being used, and the type of programs and coursework offered 
through distance education. 

To select our sample of postsecondary schools, we used enrollment data 
from Education's 2009-2010 IPEDS to identify schools that were offering 
distance education and had significant increases in total enrollment, 
which may be due, in part, to increased enrollment in distance 
education classes or programs. Based on the schools' percentage change 
in enrollment, we then selected schools by size--as defined by 
enrollment--as well as by sector and program length. We also considered 
the following factors in selecting our sample of schools: 

* geographic dispersion by state, 

* minority serving school status (e.g., Historically Black Colleges and 
Universities and Hispanic-serving institutions), 

* selectivity in accepting students, 

* industry expert or stakeholder recommendations, 

* extent to which distance education programs and courses are offered 
(totally online schools versus schools offering both campus-based and 
online instruction), and: 

* whether the schools are regionally or nationally accredited. 

Based on these considerations, we selected 20 schools representing all 
sectors and program lengths, for site visits or phone interviews (see 
app. II for a list of colleges and universities we interviewed). Our 
selected schools break out as follows: 

* 4 public 2-year schools. 

* 5 public 4-year schools. 

* 6 private nonprofit schools. 

* 5 private for-profit schools. 

After our interviews with officials from the selected schools, we 
conducted a content analysis on the information gathered. Interview 
responses and comments from officials were categorized to identify 
common themes. The themes were reviewed by a methodologist before all 
comments were categorized. One analyst coded the information and a 
second analyst assessed the accuracy of the coding. Disagreements 
between coders were resolved through discussion. We used the 
information gathered from these schools for illustrative purposes only. 
Because the schools were not selected to be representative of all 
postsecondary schools, the interview results are not generalizable to 
other postsecondary schools, including groups of schools in the same 
sector or program length. 

To determine the characteristics of students participating in distance 
education courses and programs, as well as those who do not 
participate, we analyzed Education's 2007-2008 NPSAS data, the most 
current available data.[Footnote 64] These data allowed us to compare 
distance education students to nondistance education students on the 
following characteristics: age, gender, marital status, dependent 
status, and employment status. The data also allowed us to describe the 
characteristics of students enrolled in distance education, in terms of 
type of school attended, field of study, race, veteran status, and 
disability status. We supplemented this analysis with information from 
our interviews with selected postsecondary schools and student 
demographic data provided by school officials. 

To determine how the quality of distance education programs is being 
assessed, we obtained information from accrediting agency and school 
officials and reviewed and analyzed federal laws and regulations 
related to accreditation. We interviewed officials from six accrediting 
agencies (three regional, two national, and one specialized[Footnote 
65]) and reviewed their standards and policies to determine how they 
are assessing the quality of distance education courses and programs. 
In addition, we reviewed documents from the Council for Higher 
Education Accreditation (CHEA)[Footnote 66] website, to gain a broader 
understanding of accreditation. We also interviewed officials from 
schools in our sample to describe the specific quality assurance 
frameworks and the outcomes they use to assess the performance of 
students engaged in distance education. In addition, we interviewed an 
official from Quality Matters and reviewed quality standards documents 
provided at the interview.[Footnote 67] 

To determine the extent to which Education is monitoring distance 
education programs to ensure the protection of federal student aid 
funds, we reviewed relevant federal laws and regulations regarding 
distance education oversight requirements. We interviewed officials 
from Education's Federal Student Aid office and the Office of 
Postsecondary Education to determine their roles in the monitoring and 
governance of Title IV programs, specifically with respect to distance 
education. In addition, we interviewed officials from NCES to learn 
about their IPEDS data collection efforts and Education's Office of the 
Inspector General to learn about their distance education monitoring 
activities and findings. Finally, we reviewed agency documents, 
including plans to add distance education variables to the IPEDS 
survey, OIG testimonies and reports, and an interim status memorandum 
issued by the OIG/FSA Risk Project. 

We conducted this performance audit from November 2010 to November 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: List of Colleges and Universities GAO Interviewed: 

Name of institution: Los Angeles Valley College; 
Institution type: Public, 2-year; 
Location: CA. 

Name of institution: Navarro College; 
Institution type: Public, 2-year; 
Location: TX. 

Name of institution: Seminole State College of Florida; 
Institution type: Public, 2-year; 
Location: FL. 

Name of institution: Wichita Area Technical College; 
Institution type: Public, 2-year; 
Location: KS. 

Name of institution: Morgan State University; 
Institution type: Public, 4-year; 
Location: MD. 

Name of institution: University of Central Florida; 
Institution type: Public, 4-year; 
Location: FL. 

Name of institution: University of Maryland-University College; 
Institution type: Public, 4-year; 
Location: MD. 

Name of institution: University of Minnesota-Twin Cities; 
Institution type: Public, 4-year; 
Location: MN. 

Name of institution: University of Puerto Rico-Río Piedras; 
Institution type: Public, 4-year; 
Location: PR. 

Name of institution: Baker University; 
Institution type: Private nonprofit, 4-year; 
Location: KS. 

Name of institution: Carnegie Mellon University; 
Institution type: Private nonprofit, 4-year; 
Location: PA. 

Name of institution: Columbia University in the City of New York; 
Institution type: Private nonprofit, 4-year; 
Location: NY. 

Name of institution: Inter American University of Puerto Rico; 
Institution type: Private nonprofit, 4-year; 
Location: PR. 

Name of institution: Saint Leo University; 
Institution type: Private nonprofit, 4-year; 
Location: FL. 

Name of institution: Western Governors University; 
Institution type: Private nonprofit, 4-year; 
Location: UT. 

Name of institution: American Public University System; 
Institution type: Private for-profit, 4-year; 
Location: WV. 

Name of institution: Capella University; 
Institution type: Private for-profit, 4-year; 
Location: MN. 

Name of institution: DeVry University; 
Institution type: Private for-profit, 4-year; 
Location: IL. 

Name of institution: Keiser University-Fort Lauderdale[A]; 
Institution type: Private for-profit, 4-year; 
Location: FL. 

Name of institution: National University College; 
Institution type: Private for-profit, 4-year; 
Location: PR. 

Source: GAO. 

[A] At the time of our interview with its officials in January 2011, 
Keiser University-Fort Lauderdale was a private for-profit school. 
However, shortly after our interview, the university became a private 
nonprofit school. Since we interviewed the officials as a private for-
profit with no knowledge of the school's forthcoming transition, we are 
categorizing them as a for-profit school. 

[End of table] 

[End of section] 

Appendix III: Comments from the Department of Education: 

Department of Education: 
United States of America: 

Federal Student Aid: 
Start Here: 
Go Further: 

Chief Operating Officer: 

Mr. George A. Scott: 
Director: 
Education, Workforce, and Income Security Issues: 
United States Government Accountability Office

November 3, 2011: 

Dear Mr. Scott, 

Thank you for providing the Department of Education (Department) with a 
draft cop of the U.S. Government Accountability Office's (GAO's) report 
entitled "Higher Education: Use of New Data Could Help Improve 
Oversight of Distance Education" GAO-12-39). 

This study looks at the recent growth in distance education, 
particularly the use of online education. The study discusses the 
characteristics of distance education, the characteristics of students 
participating in distance education, how the quality of distance 
education is being assessed, and how the Department monitors distance 
education. 

Following is GAO's recommendation and the Department's response: 

Recommendation: 

To help Education strengthen its oversight of its distance education, 
the Secretary of Education should direct FSA to develop a plan on how 
to best to use the new Integrated Postsecondary Education Data System 
(IPEDS) distance education data and provide input to the National 
Center for Education Statistics (NCES) on future IPEDS survey work with 
regard to distance education. 

Response: 

We agree with the recommendation. FSA will update its School 
Participation Team procedures to include consideration of IPEDS data on 
distance education for monitoring schools. Furthermore, FSA will 
provide input to NCES on the results of its IPEDS 2012-2013 survey and 
on the design and results of any future surveys that include education. 

I appreciate your examination of this important issue. The Department 
is committed to the continuous improvement of oversight of the federal 
student aid programs. 

Sincerely, 

Signed by: 

James W. Runcie: 

830 First St. N.E.,: 
Washington, DC 20202: 
[hyperlink, http://FederalStudentAid.ed.gov]: 
1-800-4-FED-AID: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George A. Scott, (202) 512-7215 or scottg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Tranchau Nguyen, Assistant 
Director; Susan Chin, Analyst-in-Charge; Amy Anderson; Jeffrey G. 
Miller; and Jodi Munson Rodríguez made significant contributions to 
this report in all aspects of the work. Susan Bernstein contributed to 
writing this report. Michael Silver, Christine San, and John Mingus 
provided technical support, and Jessica Botsford provided legal 
support. Mimi Nguyen assisted with report graphics. 

[End of section] 

Related GAO Products: 

Distance Education: Growth in Distance Education Programs and 
Implications for Federal Education Policy, [hyperlink, 
http://www.gao.gov/products/GAO-02-1125T]. Washington, D.C.: Sept. 26, 
2002. 

Distance Education: Improved Data on Program Costs and Guidelines on 
Quality Assessments Needed to Inform Federal Policy, [hyperlink, 
http://www.gao.gov/products/GAO-04-279]. Washington, D.C.: Feb. 26, 
2004. 

Higher Education: Institutions' Reported Data Collection Burden is 
Higher Than Estimated but Can Be Reduced through Increased 
Coordination, [hyperlink, http://www.gao.gov/products/GAO-10-871]. 
Washington, D.C.: Aug. 13, 2010. 

DOD Education Benefits: Increased Oversight of Tuition Assistance 
Program Is Needed, [hyperlink, http://www.gao.gov/products/GAO-11-300]. 
Washington, D.C.: March 1, 2011. 

DOD Education Benefits: Further Actions Needed to Improve Oversight of 
Tuition Assistance Program, [hyperlink, http://www.gao.gov/products/GAO-
11-389T]. Washington, D.C.: March 2, 2011. 

VA Education Benefits: Actions Taken, but Outreach and Oversight Could 
Be Improved, [hyperlink, http://www.gao.gov/products/GAO-11-256]. 
Washington, D.C.: Feb. 28, 2011. 

[End of section] 

Footnotes: 

[1] 20 U.S.C. § 1001 et. seq. Title IV of the Higher Education Act (20 
U.S.C. §§ 1070-1099d) authorizes programs that provide financial 
assistance to students attending a variety of postsecondary schools. 

[2] While this report focuses on the student financial assistance 
provided under Title IV of the Higher Education Act, the Department of 
Defense (DOD) and the Department of Veterans Affairs (VA) also provide 
financial aid for postsecondary education. In fiscal year 2010, the 
DOD's Military Tuition Assistance Program provided $531 million in 
tuition assistance to approximately 302,000 service members, while VA 
provided $9 billion in education benefits to service members and 
veterans. 

[3] 20 U.S.C. § 1003(7) and 34 C.F.R. § 600.2. 

[4] In October 2010 (75 Fed. Reg. 66,832), Education published final 
regulations to, among other things, clarify what is required for an 
institution of higher education to be considered legally authorized by 
a state (see 34 C.F.R § 600.9). To clarify these requirements for 
distance education, the department provided that a school offering 
distance education programs to students in a state where the school is 
not physically located must meet any state requirements for it to be 
offering postsecondary distance education in that state (at 34 C.F.R. § 
600.9(c)). The Association of Private Sector Colleges and Universities 
challenged Education's state authorization regulations in the District 
of Columbia U.S. District Court. In July 2011, the court declined to 
address whether the state authorization regulations exceeded 
Education's authority but vacated the paragraph related to distance 
education on procedural grounds, finding that Education failed to 
provide notice and the opportunity for comment because the paragraph 
was not included in the proposed regulations (2011 WL 2690406). Both 
parties have appealed that decision to the United States Court of 
Appeals for the District of Columbia Circuit. 

[5] The National Advisory Committee on Institutional Quality and 
Integrity (NACIQI), a body comprising higher education officials that 
meets periodically to advise the Secretary of Education on 
accreditation matters, has established a policy agenda for 2011 that 
includes a review of the roles and responsibilities of triad members, 
as well as the division of responsibility and accountability among the 
members. NACIQI is expected to provide the Secretary with its 
recommendations on this issue and others related to the reauthorization 
of the Higher Education Act. 

[6] In order to participate in Title IV programs, schools must apply to 
Education and meet minimum eligibility requirements, including those 
related to financial responsibility and administrative capability. Once 
a school's application for participation is certified, it must reapply 
for recertification at least every 6 years. 20 U.S.C. § 1099c(g). 

[7] 34 C.F.R. § 602.22. 

[8] 20 U.S.C. § 1099b(a)(5). Education is required to publish a list of 
nationally recognized accrediting agencies that the Secretary 
determines to be a reliable authority as to the quality of education or 
training provided by the schools they accredit. 20 U.S.C. § 1001(c). 
Accrediting agencies must renew their recognition with Education at 
least every 5 years. 20 U.S.C. § 1099b(d). 

[9] Higher Education Amendments of 1992, Pub. L. No. 102-325, 106 Stat. 
448. 

[10] Higher Education Reconciliation Act of 2005, Pub. L. No. 109-171, 
Title VIII, Subtitle A, 120 Stat. 4, 155 (2006). 

[11] This change was made following Education's completion of a 
mandated distance education demonstration project. The project was 
undertaken to (1) test the quality and viability of expanded distance 
education programs, (2) provide increased student access to higher 
education, and (3) determine the specific statutory and regulatory 
requirements that should be altered to provide greater access to high-
quality distance education programs. In 2005, Education reported to 
Congress that waivers of the 50 percent rule did not lead to increases 
in fraud and abuse of Title IV funds. 

[12] Higher Education Amendments of 1998, Pub. L. No. 105-244, 112 
Stat. 1581. 

[13] Pub. L. No. 110-315, 122 Stat. 3078. Both institutions and 
individual programs can be accredited. When an institution is 
accredited, all courses and programs are covered, whereas in program 
accreditation, only the specific program is reviewed. However, for 
distance education, both types of accreditation require the agency to 
have distance education in its scope of review. 20 U.S.C. § 1099b(n)(3) 
and 20 U.S.C. § 1088(b)(3). 

[14] 20 U.S.C. § 1099b(a)(4)(B). 

[15] 20 U.S.C. § 1099b(a)(4)(B)(ii). 

[16] 20 U.S.C. § 1099b(c)(1). 

[17] 20 U.S.C. § 1009b(c)(2). 

[18] Recognized accrediting agencies that do not already have distance 
education within their scope of review may add distance education to 
their scope by notifying Education in writing. Such agencies must 
monitor the head count enrollment at each school they accredit, and if 
any school experiences an increase of 50 percent or more within 1 year, 
the agency must report that information to Education and also submit a 
report outlining the circumstances of the increased enrollment and how 
the agency evaluates the capacity of the school. Education submits that 
report to NACIQI for consideration in reviewing the agency's change in 
scope. 20 U.S.C. §§ 1099b(a)(4)(B)(i)(II) and 1099b(q); 34 C.F.R. §§ 
602.19(e), 602.31(d), and 602.34(c)(1). 

[19] U.S. Department of Education, Distance Education at Degree-
Granting Postsecondary Education Institutions: 2006-07 (Washington, 
D.C.: December 2008). Data in this report are based on surveys sent to 
a nationally representative sample of approximately 1,600 Title IV 
eligible degree-granting postsecondary schools. 

[20] I. Elaine Allen and Jeff Seaman, Babson Survey Research Group and 
the Sloan Consortium, Class Differences: Online Education in the United 
States, 2010 (November 2010). The sample for this analysis is composed 
of all active, degree-granting institutions of higher education in the 
United States that are open to the public. Questions for this study 
were included in the College Board's Annual Survey of Colleges. 

[21] The university uses a competency-based model, where students' 
progress is determined by what they know as opposed to seat time or 
credit hours. The focus is on ensuring students possess the skills and 
knowledge they need to be successful. 

[22] There were a few exceptions: Students at two schools are charged 
an additional technology fee to take online courses. At another school, 
an official said the school charged lower tuition for distance 
education classes when it was less expensive to deliver--such as when 
the courses are taken on a military base that does not charge the 
school for rent. 

[23] The Integrated Postsecondary Education Data System (IPEDS) is the 
federal government's core postsecondary data collection program. All 
postsecondary schools participating in federal student financial aid 
programs are required to complete a group of annual surveys on a 
variety of topics. While IPEDS has the most up-to-date, comprehensive 
data on postsecondary schools, the only distance education data 
collected are whether an institution offers distance education 
opportunities to its students. No data on the extent of a school's 
distance education offerings are collected. Additionally, because the 
IPEDS definition of distance education course has changed over time, 
consistent trend data are not readily available. 

[24] Minority-serving institutions are defined in law for purposes of 
certain grant programs authorized under Title III and Title V of the 
HEA. The three main types of minority-serving institutions are 
Historically Black Colleges and Universities, Tribal Colleges and 
Universities and Hispanic-serving institutions. Other types of minority-
serving institutions include Alaska Native, Native Hawaiian, Asian 
American, Native American, and Pacific Islander-serving institutions. 
All institutions except Historically Black Colleges and Universities 
and Tribal Colleges and Universities are defined, in part, by the 
percentage of minority students enrolled. 

[25] Data on Historically Black Colleges and Universities and Tribal 
Colleges and Universities are derived directly as reported in IPEDS. 
GAO extracted data on other institutions from IPEDS using the 
enrollment percentages prescribed for the Title III or V grant 
programs. Separate data are not provided for Alaska Native and Native 
Hawaiian-serving institutions due to limitations with the 2009-2010 
IPEDS data. 

[26] NPSAS is a recurring nationwide survey to collect demographic 
information on postsecondary students, as well as information on how 
they fund their education. We conducted our analysis using student-
reported data from the most recent administration of the NPSAS, which 
covered students attending Title IV eligible schools during the 2007-
2008 academic year. NPSAS surveys include a number of questions related 
to distance education. 

[27] Of the approximately 5 million distance education students, 4.28 
million were undergraduates, 741,000 were graduate students, and 22,000 
were first-professional students. A first-professional student is a 
student who is enrolled in a degree program that encompasses certain 
occupationally specific programs such as law and medicine. In total, 
there were an estimated 24.4 million postsecondary students, including 
20.9 million undergraduates, 3.2 million graduate students, and 282,000 
first-professional students in the 2007-2008 school year. 

[28] When we cite differences in student characteristics between 
distance education students and students who did not take any distance 
education courses, the differences are statistically significant at the 
95 percent confidence level. 

[29] For the analyses of distance education participation among 
students of different races and ethnicities, military status, and 
disability status, first-professional students are included, as well as 
undergraduate and graduate students. 

[30] GAO, Distance Education: Growth in Distance Education Programs and 
Implications for Federal Education Policy, [hyperlink, 
http://www.gao.gov/products/GAO-02-1125T] (Washington, D.C.: Sept. 26, 
2002). 

[31] Likely as a result of working full time more often, graduate 
students taking a distance education course or program also had higher 
average incomes than graduate students who took no distance education. 
In addition, students in the lowest income quartile (the lowest 
25percent of income) enrolled in distance education courses or programs 
less often than students with higher incomes. 

[32] As might be expected, distance education students more often 
attend school part time. For undergraduates, about 43 percent of the 
students who took distance education courses or programs were part-time 
students, while about 33 percent of the students who did not take any 
distance education courses were part-time students. This trend also 
occurred among graduate students (about 59 percent of those who took 
distance education courses or programs were part-time students compared 
with about 45 percent of those who did not take any distance education 
courses). 

[33] When we say all races and ethnicities, we are referring to all 
races and ethnicities reported by students to the NPSAS. 

[34] In addition, of all students taking distance education courses or 
degree programs, a greater percentage of white students took distance 
education courses or programs when compared to other racial and ethnic 
groups. White students represented about 66 percent of all students who 
took distance education courses or programs compared with about 61 
percent of students who took no distance education courses or programs 
and about 62 percent of students overall. 

[35] Veterans and service members may be eligible to receive 
educational benefits from either the Department of Veterans Affairs or 
the Department of Defense when participating in a variety of programs, 
including distance education. See GAO, VA Education Benefits: Actions 
Taken, but Outreach and Oversight Could Be Improved, [hyperlink, 
http://www.gao.gov/products/GAO-11-256] (Washington, D.C.: Feb. 28, 
2011); DOD Education Benefits: Increased Oversight of Tuition 
Assistance Program Is Needed, [hyperlink, 
http://www.gao.gov/products/GAO-11-300] (Washington, D.C.: Mar. 1, 
2011). 

[36] Disability data are student-reported and taken from NPSAS. Data on 
the rates at which reservists with disabilities took distance education 
courses or programs were not sufficiently reliable to report. 

[37] While we analyzed distance education participation for students 
with disabilities, we did not evaluate issues of accessibility for 
these students. 

[38] The percentage of students taking distance education courses and 
programs who had any type of disability was not significantly higher 
than the percentage for students taking no distance education. However, 
the percentage of students taking distance education courses and 
programs who had disabilities specifically affecting their mobility was 
significantly higher than the percentage for students taking no 
distance education. Percentage differences were not significant for 
students with other types of disabilities, including visual 
impairments, hearing impairments, learning disabilities, and mental 
conditions. 

[39] This is lower than the general student population, which averages 
about 25 percent of enrollments online. However, the percentage of 
online enrollments increased for students with physical impairments (26 
percent) and visual impairments (35 percent). 

[40] Schools can be institutionally accredited by regional or national 
accrediting agencies, or both, and may also have degree programs in 
certain fields of study accredited by specialized accreditors. The 
seven federally recognized regional accrediting agencies review schools 
in their prescribed geographic region of states, whereas the seven 
federally recognized national accreditors can accredit schools across 
the United States. Regional accrediting agencies tend to accredit 
degree-granting colleges and universities, while national accrediting 
agencies tend to accredit non-degree-granting career schools. Nineteen 
of the 20 schools we interviewed were regionally accredited and 3 were 
nationally accredited, with 2 schools receiving both regional and 
national accreditation. 

[41] 20 U.S.C. §§ 1099b(a)(4) and 1099b(a)(5); 34 C.F.R. §§ 602.16 and 
602.17. 

[42] In addition to reviewing the roles and responsibilities of Triad 
members, NACIQI has been assessing ways to improve the accreditation 
process. In exploring ways accreditors can better use data to assess 
program quality, members have discussed the benefits and drawbacks of 
standardized learning outcomes. 

[43] 20 U.S.C. § 1099b(c)(1). 

[44] 20 U.S.C. § 1099b(c)(1). 

[45] Among other requirements for recognition by Education, accrediting 
agencies must have substantive change policies that meet certain 
requirements as prescribed by Education.
34 C.F.R. § 602.22. 

[46] In 2006-2007, about 94 percent of schools that offered distance 
education courses developed them in-house. U.S. Department of 
Education, Distance Education at Degree-Granting Postsecondary 
Institutions, 2006-07 (Washington, D.C.: December 2008). 

[47] In September 2011, Education's OIG reported that, over the past 6 
years, it had conducted numerous investigations of fraud involving 
distance education programs. Primarily, these investigations centered 
around fraud rings whereby a ringleader posing as a student facilitates 
enrolling other "straw students," those who may not be eligible or do 
not intend on attending class, in order to collect Title IV student 
federal aid. For the full report, see Department of Education, Office 
of Inspector General, Investigative Program Advisory Report, Distance 
Education Fraud Rings, L42L0001 (Washington, D.C.: Sept. 26, 2011). 

[48] The OIG reported that distance education might represent increased 
risk for student federal aid programs as early as 2000. According to 
the Acting Inspector General's October 14, 2009, testimony before the 
Higher Education, Lifelong Learning, and Competitiveness Subcommittee, 
House Committee on Education and Labor, the potential for fraud in 
distance education stems from the difficulty in verifying student 
identity and ensuring that enrolled students are engaged in academic 
activity, given the limited or no face-to-face contact. The Acting 
Inspector General said that the rapid growth of distance education, 
combined with the paperless delivery of student aid funds (i.e., 
schools may not have an in-person relationship with the student), makes 
distance education vulnerable to fraud. Additionally, in fiscal year 
2011, the OIG identified distance education as a management challenge 
for the department and started an audit reviewing the extent to which 
Education has adapted Title IV regulations to address these issues. 

[49] FSA officials said in recent years they have conducted about 200 
program reviews per year. The reviews assess a school's institutional 
eligibility, financial responsibility, and administrative capability 
for participating in Title IV student aid programs. Schools are 
selected for program reviews based on specific risk indicators, such as 
a referral or complaint, or as a result of a comprehensive compliance 
review, although officials said schools that do not meet these criteria 
may also be selected. 

[50] Specific dates covered by program reviews and audits that had 
issued final determinations were October 1, 2005, through May 25, 2011. 
Substantive interaction was not required until 2008 when the Higher 
Education Opportunity Act added the definition of distance education to 
the HEA, which included that requirement. Pub. L. No. 110-315, § 
103(a)(1), 122 Stat. 3078, 3087 (2008). 

[51] FSA used several indicators to identify a school's risk, including 
a change in school sector (e.g., from proprietary to private nonprofit 
or from private nonprofit to proprietary), an audit or investigation by 
the OIG, and the distribution of a high percentage of full student 
loans, as this may be an indicator that a school is not appropriately 
monitoring student withdrawals for return of student aid funds. 

[52] FSA officials said they conducted 25 reviews and the OIG is 
conducting 2 audits. 

[53] Representatives from the following Education departments also 
participated: Office of the Secretary, Office of the Undersecretary, 
Office of the General Counsel, and Office of Postsecondary Education. 

[54] In previous work, we found that, in fiscal year 2009, 71 percent 
of courses taken by military members using tuition assistance were 
distance education courses (see [hyperlink, 
http://www.gao.gov/products/GAO-11-300]). 

[55] The 27 schools were selected from an initial list of 2,710 schools 
identified as offering some distance education. As of September 7, 
2011, FSA reported that it had finalized and issued reports for 11 
schools for which there were no findings related specifically to 
distance education. 

[56] Schools may need to apply for recertification more frequently if 
they, for example, change their ownership or status. 34 C.F.R. § 
600.20(b). 

[57] NCES is the primary federal entity for collecting and analyzing 
data on the condition of education in the United States and other 
nations. 

[58] According to GAO's standards for internal control, program 
managers need operational data to determine whether they are meeting 
their agency's goals for accountability for effective and efficient use 
of resources. See GAO, Standards for Internal Control in the Federal 
Government, [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[59] An NCES official said NCES provided a comment period after the 
publication of the technical review panel's suggested changes and the 
proposed changes were also published in the Federal Register. 

[60] GAO, Federal Student Loans: Patterns in Tuition, Enrollment, and 
Federal Stafford Loan Borrowing Up to the 2007-08 Loan Limit Increase, 
[hyperlink, http://www.gao.gov/products/GAO-11-470R] (Washington, D.C.: 
May 25, 2011). 

[61] U.S. Department of Education, Distance Education at Degree-
Granting Postsecondary Education Institutions: 2006-2007 (Washington, 
D.C.: December 2008). 

[62] The Sloan Consortium is a membership organization that helps 
schools and professionals improve the quality, scale, and breadth of 
online education through conferences, workshops, and research. 

[63] I. Elaine Allen and Jeff Seaman, Babson Survey Research Group and 
the Sloan Consortium, Class Differences: Online Education in the United 
States, 2010 (November 2010). The Sloan Consortium, in conjunction with 
the Babson Survey Research Group, conducts an annual survey of a sample 
of degree-granting schools of higher education in the United States. 
For the 2010 report, 2,583 schools responded to the survey--a 57 
percent response rate for the sample universe of 4,511 schools. The 
schools that responded represent 80 percent of higher education 
enrollments. 

[64] NCES collects characteristics of students studying at 
postsecondary schools using a nationally representative sample through 
the NPSAS survey every 3 to 4 years. 

[65] The three regional accrediting agencies are the Middle States 
Commission on Higher Education; the Western Association of Schools and 
Colleges, Accrediting Commission for Community and Junior Colleges; and 
the Western Association of Schools and Colleges, Accrediting Commission 
for Senior Colleges and Universities. The two national accrediting 
agencies are the Accrediting Council for Independent Colleges and 
Schools and the Distance Education Training Council. The specialized 
accrediting agency is the Commission on Collegiate Nursing Education. 

[66] CHEA is a national association of schools and accrediting agencies 
that advocates for accreditation and recognizes accreditors. 

[67] Quality Matters was started through a Fund for the Improvement of 
Postsecondary Education grant given to Maryland Online, a consortium of 
colleges and universities in Maryland. It is a fee-based, nonprofit 
program that certifies the quality of online and blended courses 
through a peer review process. 

[End of section] 

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