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##  Understanding the Implications of Distance Learning for                         Accreditation and Licensure of Counselor Preparation Programs.                  ERIC/CASS Digest.                                                            

Accreditation and licensure standards, which have been built around             the traditional classroom paradigm for delivery of higher education,            must shift radically to accommodate the use of new distance learning            technologies. Furthermore, the movement from teacher-centered to                learner-centered environments results in a need for the                         accreditation and licensure paradigms to be reevaluated in order                to (1) remain relevant, (2) carry out their original functions of               accountability, quality assurance, and consumer protection, and (3)             not impede the development of distance learning programs. THE NEED            FOR OUTCOMES ASSESSMENTAccreditation standards have                         traditionally evaluated identifiable physical facilities,                       faculty-to-student ratios, library holdings, support staff, and                 budgets as well as course syllabi, faculty credentials, history of              graduates, and the like. These types of standards are collectively              referred to as inputs assessment and measure the capacity of an                 institution or program to carry out its educational mission.  But,              are these standards relevant in a distance learning environment? For            example, in the case of a virtual university how would an                       accreditation site visit be meaningful when all the accreditor will             see are offices full of humming and whirring computer disk drives?              Faculty-to-student ratios have little meaning when any number of                students can pursue an on-line course without time and place                    constraints.  There also may be no library to visit if access is                provided either to computerized databases or to libraries by way of             the Internet. 
In the 1980s, some farsighted accreditors began                 shifting from inputs assessment to outcomes assessment standards                that evaluate the success of the institution or program in                      accomplishing its mission. More specifically, outcomes assessment               evaluates how well the institution or program transfers knowledge               and skills to students. However, there has been resistance to this              shift and progress has been slow.  First, it is harder to do.  It is            much easier to count faculty, clock hours, and review budget figures            than it is to determine if those inputs are leading to successful               outcomes.  Second, some view inputs standards as tools for                      protecting faculty lines, workloads, and resources -- a position                that often infuriates administrators.  Third, outcomes assessment               has been viewed as the province of agencies that certify or license             individuals to practice. 
But these objections are based on an                 unnecessarily narrow view of outcomes assessment that, if done                  correctly, can perform the critical function of determining whether             changes are needed in the inputs.  Additionally, there is growing               pressure from the U.S. Department of Education (1997) and the                   Council for Higher Education Accreditation (1998) to require                    validation of standards in terms of relevancy to outcomes. Finally,             since distance learning defies the application of many traditional              input standards, it will force accreditors in the direction of                  outcomes assessment.  When learning occurs via new delivery methods,            accreditors must ask new questions regarding what constitutes                   quality education. They must review their existing standards against            these questions and revise the standards to insure quality within               the new learning paradigm.  Such questions include the                          following: 
* First and foremost, what is being accredited? Is it              an institution, a program of study, a delivery system, or something             else? 
* Who are the faculty?  What support is provided to faculty             who engage in distance learning? 
* Who are the students and how               are they evaluated?  How do students interact with faculty? Is the              delivery system accessible to disabled students? 
* What                       instructional designs best fit with the mode of education delivery?             How are labs and clinics conducted? 
* What library facilities are             available? 
* How is privacy of student data, verification of                  student identity, and protection of intellectual property                       secured? 
Once the fundamental questions have been answered,                   standards should be examined to determine if they adequately assess             the appropriate factors without constraining innovation. LICENSURE            AND REGULATION OF DISTANCE LEARNINGUnlike the collegial peer                process that lies at the heart of accreditation, licensure of                   educational institutions and programs is usually conducted by                   bureaucrats under legislative mandate.  There is nothing collegial              about it.  Although licensing laws prescribe "standards," these                 differ from accreditation standards in that they focus on                       amenability to legal process, fiscal accountability, and compliance             with state and federal laws. However, accreditation and licensure               have become commingled because many licensing laws require                      accreditation as a condition of licensure. 
Because each State has             legal authority to regulate education within its own borders, there             are at least 51 different regulatory schemes (including the District            of Columbia's) with which a distance learning program may have to               contend just to operate within the United States.  This multiplicity            of regulations presents difficult problems for distance learning                programs desiring to offer courses across jurisdictional lines.                 Identification of the applicable regulations, multiple applications             and fees, periodic audits and reporting to each jurisdiction are                just a few obstacles to be overcome (Western Governors Association              Design Team, 1996). Identifying a state's regulations can be                    daunting because most states make no explicit mention of distance               learning in their regulations. Reference must be had to broader                 rules governing out-of-state and nonpublic educational institutions.            After the relevant set of regulations has been identified, it is not            always clear that those regulations will even apply to a given                  distance learning program.  In most states the institution must have            some physical presence within the state before the requirements                 apply. But the definition of physical presence varies widely.  Many             states exercise jurisdiction only if faculty or administrative                  personnel are present within the state (Goldstein, 1998).  Others               exercise jurisdiction if academic credentials are granted to                    residents within the state.  A few assert jurisdiction if                       instruction is given to state residents by correspondence,                      telecommunications, or electronic media. 
The scope of regulation              varies also, ranging from simple registration of institutions and               programs to requiring that highly specific standards be addressed               within a complex application process. An example of the latter is               Florida, which requires a four-step process moving from temporary               licensure to "provisional level one" to "provisional" and finally               to "regular" licensure. 
Accreditation could provide a valuable                service in reducing these regulatory burdens if licensing agencies              would accept accreditation as satisfaction of most licensing                    requirements. This approach pares down those requirements to such               things as providing the address of a registered agent for service of            process, proof of insurance, and other such guarantees of legal and             public accountability. RECOMMENDATIONSThe historical reason               for accreditation and licensing in the United States has not                    changed. The public's need for reliable information about education             programs is even greater in the distance learning environment.                  Accreditors should be empowered to think creatively and                         cooperatively, so their standards and processes remain relevant and             foster the development of quality distance learning programs.  The              following recommendations are suggested. 
1. Rewrite standards to              make them outcomes versus inputs oriented.  Accreditors should                  review standards to determine if they unnecessarily impede                      innovation in the design and implementation of nontraditional                   delivery systems.  Standards should be written to assess outcomes               rather than inputs. 
2. Educate the public about accreditation of              distance learning.  As the Internet makes it easier for fraudulent              diploma mills to prey on the public (Guernsey, 1997), accreditors               must recognize that the demand for information will not go away.                Accreditors must educate the public about their standards and                   quality assurance processes and inform them about questions they                need to ask. 
3. Encourage cooperation and collaboration between               and among accrediting agencies and licensing authorities.                       Accreditors and licensing agencies should be encouraged to cooperate            to reduce duplication of effort by educational programs that cross              regional or programmatic boundaries. Laws could be rewritten to                 accept accreditation as satisfying some licensing                               requirements. CONCLUSIONBecause the paradigm for delivery of              higher education is shifting so markedly in the distance learning               environment, accreditors and licensure authorities will face new                challenges in determining what constitutes quality education.                   Standards that have traditionally quantified inputs must be altered             to measure student learning outcomes. However, knowing where, when,             and how to alter standards is not easy.  Accreditors and licensing              authorities have had little time to define what constitutes good                practices and standards for distance learning programs.  It is                  imperative that accreditors and licensing authorities immediately               begin working together to create a quality assurance system that is             relevant to new learning environments and protective of the public's            interest. REFERENCESCouncil for Higher Education                          Accreditation.  (1998, September 28).  Recognition of accrediting               organizations:  Policy and procedures.  Washington, DC:                         Author.  (Available from CHEA, National Center for Higher Education,            One Dupont Circle, NW, Suite 510, Washington, DC                                20036-1135) 
Goldstein, M. B.  (1998, June).  Regulatory                       implications of distance learning:  The external environment.  Paper            presented at the annual conference of the National Association of               College and University Attorneys, Philadelphia, PA. 
Guernsey,                 L. (1997, December 19).  Is the Internet becoming a bonanza for                 diploma mills? The Chronicle of Higher Education, pp.                           A22-A24. 
U.S. Department of Education Procedures and Criteria for             the Recognition of Accrediting Agencies, 34 C.F.R. SS                           602.20-.30 (1997). 
Western Governors Association Design                       Team. (1996, July). The policy environment for implementing the                 Western Governors University. Denver, CO: Author [On-line].                     Available:                                                                      http://www.wgu.edu/wgu/about/policyenviron.html. 
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Carol L.             Bobby is the Executive Director of the Council for Accreditation of             Counseling and Related Educational Programs (CACREP). 
Lucien                  Capone III is University Counsel for the University of North                    Carolina at Greensboro. 
ERIC Digests are in the public domain and             may be freely reproduced and disseminated.  This publication was                funded by the U.S. Department of Education, Office of Educational               Research and Improvement, Contract No. ED-99-CO-0014. Opinions                  expressed in this report do not necessarily reflect the positions of            the U.S. Department of Education, OERI, or ERIC/CASS.                        **Title:** Understanding the Implications of Distance Learning for                         Accreditation and Licensure of Counselor Preparation Programs.                  ERIC/CASS Digest.                                                            **Document Type:** Information Analyses---ERIC Information Analysis Products (IAPs) (071); Information Analyses---ERIC Digests (Selected) in Full Text (073); **Available From:** ERIC Counseling and Student Services Clearinghouse, University of               North Carolina at Greensboro, 201 Ferguson Building, P.O. Box 26171,            Greensboro, NC 27402-6171. Tel: 336-334-4114; Tel:                              800-414-9769 (Toll Free); Fax: 336-334-4116; E-mail:                            [email protected]; Web site: http://ericcass.uncg.edu.                       **Descriptors:**  Accreditation (Institutions), College Outcomes Assessment,                      Counselor Certification,  Counselor Training,  Distance Education,             Higher Education, Standards, State Regulation                                **Identifiers:**
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