Let’s Engage in a Much-Needed Worldwide Discussion on the Need for and Best Use of Digital Learning Policy

Governments see online learning as a means of increasing access to quality learning, enabling flexibility for learners, lowering costs of higher education and a way of enabling collaboration between institutions through co-development of programs, courses and through credit transfer. But online learning creates significant policy challenges – financial arrangements to support part-time, anytime, anywhere learners; quality assurance for online learning; cyber-security for personal information; and completion rates of online versus face-to-face teaching.

Here we explore several areas of public policy, using examples from Canada, the United States, Europe and selected other jurisdictions. We focus on key issues which will shape the development of online learning, given the challenges of changing demographic, economic and social realities. The coming disruption of work (see here), the need to rethink several features of social and economic policy (see here for a Canadian perspective) and the need to embrace technology as a means of increasing access to and success in higher education (see here for a Canadian perspective) are all part of current policy conversations. Several jurisdictions are exploring significant policy shifts to enable increased access, more flexible systems and a better return on investment. We explore policies from governments around the world, including Canadian provincial and federal government policy positions.

Online learning is not a homogenous concept and practice – the term embraces a wide range of practices. There are a wide range of approaches to online learning that have very specific implications for the issues of cost, quality, access and impact. Many Massive Open Online Courses (MOOCs) resemble correspondence education or a “drop-off-and-go” model with courses running on their own with very little additional instructor/institution involvement and very little (if any) compulsory peer-to-peer interaction. Such online offerings may be very low in cost (to the institution and students), may be high in quality (depending on the assessment/validation of learning) and hugely accessible to students. On the other end of the spectrum are highly interactive and technology rich courses with low instructor: student ratios, very high levels of engagement from both instructors and students, and state of the art and current audio-video productions. Policy makers need to take a nuanced approach, recognizing that different kinds of online learning need different kinds of policy support, regulation and evaluation. The Government of South Africa policy document, Policy for the Provision of Distance Education in South African Universities in the Context of a Post-School System, is example of this.

We explore the following eight key areas of digital policy:

1. Increasing access to quality learning through online learning
2. Access to learning for specific underrepresented groups
3. Quality assurance for online learning
4. The use of open educational resources
5. Funding policies with respect to both learners and institutions
6. Support and encouragement for institutional collaboration in teaching and learning
7. Cyber security and privacy of learner data for online learners
8. Accountability and key performance indicators for online learners

 Not all policy issues can be addressed in this single document; despite their impacts on teaching and learning, policies concerning collective bargaining, purchasing policies which can affect cost structures and research and innovation are not included.

Our intent is to make available a resource to those engaged or interested in public policy related to online learning, as well as to encourage exploration, debate and engagement.

1. Increasing Access to Quality Learning Through Online Learning

Policy Options:

• Creating lighthouse institutions to shape systems behaviour
• Shifting the ground rules for program delivery
• Creating incentives for development – fees and funds
• Funding of experimental programs which have the intention of changing practices in the system as a whole

China outlined aggressive policies to increase access to higher education through distance education and online learning in the 1999-2000 educational plan from the Ministry of Education. Pilot institutions were used to test and develop effective approaches to online learning, and these tests led to some major investments in web institutes within universities. By 2005, there were 68 of these web institutes serving 17% of the total higher education student population (approximately. 3.2 million learners)[1]. This strategy – creating lighthouse institutions to shape system behaviour – is a common strategy. It is the one that lead to the creation of The Open University (UK)[2], Athabasca University (Canada) and many other open and distance education colleges, polytechnics and universities around the world (for a searchable catalogue, see here). Whether such a strategy is successful is a different matter. In some cases, bold strategic innovations have not led to major system change or to system transformation, as is the case for Western Governors or UNISA in South Africa. Though important in their own right, these institutions may have encouraged others to explore blended and online learning but have not led to the kinds of broader change envisaged when their creation was announced.

Similar developments occurred in other jurisdictions. For example, the University Grants Committee (UGC) in India has actively promoted the growth and development of online learning. India has approximately 800 universities, 39,000 colleges and 12,000 stand-alone institutions catering to around 30 million students. Despite the size of the sector, the gross enrolment in higher education is just 24%, way below that of the leading economies of the world. With limited government spending on education, online education is seen as a way not only of spurring access but also of enabling quality review and assurance. In 2017, the UGC shifted away from a position that no more than 20% of a degree program could be secured through online learning and Massive Open Online Courses (MOOCs) to a position where whole degrees (except in the fields of engineering, medicine, dentistry, pharmacy, nursing, architecture and physiotherapy) could be obtained entirely through online learning[3]. This is a system-wide change – another form of policy, known as shifting the ground rules for program delivery. Historically, the Indira Gandhi National University (IGNOU) had been permitted to offer degrees through distance and open education, following the passage of legislation in parliament in 1985. Similar permissions were given to the twelve State open distance education universities, accredited through authorizations by the Distance Education Council, established at the same time as IGNOU. IGNOU itself currently serves in excess of four million learners.

The Government of Malaysia used this policy strategy – shifting the rules - to enable the introduction of MOOCs to be used as a means of accessing the first two years of university education in their public universities. The education blueprint for Malaysia calls for all required, common courses for the first two years of undergraduate study to be available by MOOC and for credits gained through MOOCs to be acceptable by all universities. It also calls for blended learning to be the dominant mode of delivery for all programs and courses. The aim is to have 30% of all degree programs delivered through MOOCs by 2020.

A third policy strategy, seen in a variety of jurisdictions, involves government creating incentives for the development of online and flexible learning. The well-known online learning academic and researcher, Tony Bates observes[4] that “several provincial governments in Canada and federal and state governments in the USA have encouraged online learning through targeted funding. For instance, several provinces have set up e-campuses to provide funding for online courses, open textbooks and open educational resources, for faculty development opportunities, and for shared services, to encourage online learning.” Ontario has, on several occasions, created bids for funds to encourage the design, development and deployment of online learning.

Governments can also impact the growth and development of online learning through fee policies that regulate what students pay. In Nova Scotia, for example, the recent decision to abolish fees for apprenticeship programs[5] coupled with a policy of harmonizing apprenticeship regulations and access across the Atlantic provinces[6] will facilitate the growth of e-apprenticeship courses, already significant in the region, especially through the virtual apprenticeship campus in Nova Scotia[7].

More dramatically, we can see the negative impact of such policy changes, for example when the funding rules for part-time students change or when the economic context in which the policy was developed changes significantly, creating unintended consequences. When the UK changed the rules, it had significant negative impact, according to Garret[8]:

“The primary cause of the distance learning drop [in the UK] was higher tuition fees and reduced public funding for part-time undergraduates. Almost all domestic distance learners in UK higher education study part-time. Distance enrollment held up better than part-time numbers overall, which almost halved over the period.

The UK’s largest distance institution, the Open University, dropped from 209,000 to 126,000 students between 2009/10 and 2015/16. Other institutions saw distance enrollment rebound in recent years but the total is still short of the 2009/10 baseline, and some 64,000 domestic distance students are scattered across 124 colleges and universities”.

A part of financial policy that can impact the adoption of online learning is whether or not online programs qualify for student tax credits. In some jurisdictions, online learning is not seen as an acceptable form of formal learning, attracting such credits. Canadian tax regulation relevant to this issue differentiates for universities outside Canada:

2.19 For 2007 and subsequent years, the requirement in paragraph 118.5(1)(b) for full–time attendance at a university outside Canada in a course leading to a degree can be met through online attendance. However, the university must be able to establish that the enrolment of a student at the university constituted full–time attendance, such as through scheduled, interactive, course-related activities conducted over the Internet (for example, the use of online course rooms, live online conferences, chat lines and/or virtual libraries).

2.20 On the other hand, correspondence courses, either by mail or over the Internet, are generally courses that require little or no significant interactive, scheduled sessions with either the instructor or other students. e-Mail is typically used to correspond with an instructor, to submit assignments, or to access an online database or class website. As such, the requirement for full–time attendance at a university outside Canada for a correspondence course will not generally be satisfied. Prior to 2007, the requirement for full–time attendance could only be met through physical attendance at the university.

Tuition fees paid for correspondence courses may be eligible for the tuition tax credit if taken with an educational institution in Canada, but not if taken with a foreign educational institution, since paragraph 118.5(1)(b) requires full–time attendance (see 2.20) and paragraph 118.5(1)(c) requires physical commuting to the institution[9].

A final policy domain in which governments can impact access is through the funding of experimental programs, which have the intention of changing practices in the system as a whole. The Government of New Zealand in 2017 invested in pilot projects offering micro-credentials – short, modular programs, which have value individually, but which can also be “stacked” into certificate, diploma and degree programs[10]. The success of these pilots then led to proposals for system-wide change and a major consultation document[11]. In the US, the Department of Education is funding projects related to assessment-only degrees and qualifications, building on the success of such programs at the University of Wisconsin, which offers flex-based degrees in commerce, technology, nursing where the student only needs to complete assessments of learning to gain the credential. Colleges and universities in New Hampshire, Ohio, Michigan, Arizona now also offer such credentials, all of which are supported by online learning resources.

2. Access to learning for specific underrepresented groups

• Policy Options
• Appropriate academic preparation prior to entry to colleges and universities – support above and beyond that provided in “standard” compulsory education.
• Investing in social supports to complement academic supports, especially in the initial stages of post-secondary education.
• Helping learners navigate the admission and acceptance processes.
• Provide targeted financial assistance.
• Encourage system-wide reform to enable higher rates of completion for targeted students.

The Government of Ontario has long made the case that certain learner groups are underrepresented in post-secondary education – First Nations, first generation post-secondary learners, single parents, disabled learners, students in remote and rural communities, recent immigrants, members of minority language groups, and prisoners[12]. This challenge is also at the heart of many government policy initiatives around the world. Schultz and Mueller (2006)[13] review specific US programs focused on underrepresented groups which demonstrate effective outcomes and in doing so identify the key components of such programs. These are:

• Appropriate academic preparation prior to entry to colleges and universities – support above and beyond that provided in compulsory education.
• Investing in social supports to complement academic supports, especially in the initial stages of post-secondary education.
• Helping learners navigate the admission and acceptance processes for college, polytechnics and universities.
• Provide targeted financial assistance.
• Encourage system-wide reform to enable higher rates of completion for targeted students.

A similar catalogue has been developed by others, such as Zhao (2012)[14] and Berger (2009)[15].

However, the underlying reasons for underrepresentation relate to complex inter-generation, economic and social factors, which new modes of delivery cannot, of themselves, address. There is ample evidence that education does not necessarily change the broader social inequalities in a specific context. As inequality rises in many developed countries, the challenges of using policy to seek to counterbalance a major trend become more substantial[16].

Governments have done a variety of things to enable appropriate academic preparation prior to entry to colleges and universities – support above and beyond that provided in “standard” compulsory education. These include:

• Significant investments in literacy and numeracy education over and above that provided in primary and secondary schools – see here for an example.
• The development of dual credit programs, enabling students in secondary schools to complete some of their post-secondary learning in school, requiring changes in policy with respect to teaching loads, credit recognition and transfer credit.
• Requiring students in school to acquire work experience – see here for an example.
• Targeting specific groups and providing additional support – e.g. First Nations learners (see here) or students with special needs (see here).
• Changing the residency requirements (how many courses must be completed at the institution) for post-secondary programs, which enables more flexible approaches to both credit transfer, prior learning and skills recognition and more open admission.

Another related development is the widespread use of online learning in school systems. In Ontario, for example, the agreement between the Ministry of Education and D2L to provide an LMS infrastructure for every school in Ontario means that a great many learners leave school with significant experience of both blended and fully online learning, which prepares them well for flexible online learning at the college and university level.

Colleges, and universities also provide social supports to complement academic supports, especially in the initial stages of post-secondary education. For example, a number of institutions have allocated funding to student success centres, such as that at McMaster University in Hamilton, Ontario or Aurora College in Yellowknife, NWT, Canada). Some institutions are using predictive analytics to trigger fast intervention when a learner shows signs of dropping out, not making sufficient progress or failing. Rio Salado College in Arizona, for example, has developed a world-class approach to this work. The Open University of Hong Kong is also pioneering machine intelligence support systems to support learners. Many of these developments have been enabled by specific grant allocations from government agencies or from other forms of government sponsorship. While there are increasing concerns about privacy and related risks (here) from such technologies (see below), the use of these adaptive learning technologies is growing (see here).

One area in which government policy, enabled through legislation, has had a major impact is accessibility for learners with disabilities. The US has such legislation at the national and state level and Canada is moving to improve its national law (significant legislation already exists and each province also has legislation, such as that in Ontario). Such legislation has a particular impact on e-learning, well documented by Gay (2014)[17]. In the US, a critical look at similar issues for e-learning is provided by Seale (2006)[18].

A third area in which government policies impacts access by underrepresented groups relates to reducing the complexity of admission. Here, policies and procedures coupled with investments in support systems can make a significant difference. Helping learners navigate admissions and acceptance systems can enable more of the targeted learners not only secure admission but to do so to an institution best geared to meet their specific needs. Particularly helpful is moving from institutionally based applications (the learner applies to each institution) to a systems approach to admission, through organizations such as the Ontario Universities Application Centre, Ontario College Application Centre or the UK’s UCAS. While the latter is an independent charity, other similar organizations are created and funded by government or their agencies. Not only do they manage the workflow aspects of admissions, they generally also offer advice and assistance related to best matches between what the learner is seeking and what the institutions provide and issues of financial and related supports (housing, help with special needs, transportation). The increasing use of artificial intelligence chatbots to support this work is a relatively recent development. Some of the organizations offering these services are using e-learning materials to help learners navigate this process – offering decision making courses and courses on interviewing techniques. Policies may also be changed to permit learners to enroll in courses earlier, with Athabasca University lowering the admission age for university courses to 16 or Ontario enabling mature admission to a college for any adult who is 19 years of age and out of school for a minimum of a year.

Providing targeted financial assistance is another policy to encourage underrepresented groups to attend college, polytechnic or university. Some of this is achieved through targeted scholarships or bursaries. For example, the Canadian province of New Brunswick offers Tuition Access Bursary, a non-payable upfront grant for New Brunswick students attending a publicly-funded New Brunswick college or university and whose gross household income is less than $60,000 a year, aiming to attract more first-generation learners and single parents. Ontario has a similar strategy, although the household income level is $50,000. In the UK, the government in partnership with the charitable organization Become has targeted young people in care as an underrepresented group in terms of access to higher education. By coordinating available funding, offering counselling and support through the Care Advice Line and other forms of guidance it seeks to significantly impact access for this targeted group of learners (see here). They also use face-to-face and online learning to train care providers and colleagues in universities and colleges to support this targeted group of learners.

System-wide reform can benefit all in post-secondary education, but work placements are an example of broad-based initiatives that can be targeted to underrepresented groups to build confidence, capabilities and skills. This links to e-learning in that the capture of the learning from such work is generally linked to an e-portfolio – an electronic record of skills, projects and achievements beyond formal program credits, including those acquired through online learning. Many jurisdictions either require or support such a portfolio for each learner – something that the learner manages and keeps throughout their lifelong learning journey.

Other examples of system-wide reform aimed at increasing access which can also be used to support underrepresented groups with innovative approaches to learning include:

• Reforms of the supply side of the higher education sectors: For example, the Bologna reforms allow for a more modular design of higher education and standardized structures for credentials across the Eurozone. This has in turn encouraged greater flexibility in delivery, acceptance of transnational credit transfer, encouragement of prior learning, more widespread use of online learning - all leading to modest increases in access by targeted groups within the European Union.
• Reshaping the higher education landscape: This includes reforming college and universities - giving them more autonomy and flexibility with accountability, including social responsibility - see van der Ploeg & Veugelers (2008)[19], CHEPS (2008)[20]. A particular example in Canada is Ontario’s recent adoption of legislation enabling degree granting by Indigenous Institutes, which will require further policy development concerning transfer credit and credit recognition by other institutions.
• Reshaping the incentives of higher education institutes to improve and widen access for specific groups: This includes grants to institutions to develop special initiatives and core funding linked to achieving targets of students within particular groups, as has been seen in the UK, Ireland and Flanders.
• Reforming some institutions and introducing new institutes for higher education, including polytechnics, open universities, distant learning organizations and networks which can broaden access to higher education.
• Developing unique institutions aimed at responding to these needs, such as the new Francophone University in Ontario or enhancing the role of indigenous institutions in the post-secondary system, also something occurring in Ontario.

3. Quality Assurance for Online Learning

Policy Options:

• Strengthening institutional evaluation and review processes to take full account of institutional capacity for blended and online learning.
• Develop program and course quality standards that reflect best practice in online learning.
• Develop and support transnational qualification frameworks to permit learner mobility.

Historically, the value and nature of online learning have been questioned, despite the evidence that there are no significant differences in learning outcomes between online and face-to-face learning. For example, the National Open University of Nigeria (NOUN), which was founded in 1983, was suspended by the Government of Nigeria in 1984 because of a lack of confidence in distance education and the idea of open admission. It did not fully re-open until 2003. Even so, online degrees are not fully accepted within Nigeria if they come from foreign universities, though those offered by NOUN are fully accredited by the Nigerian Government. Other governments are also cautious – China will only accept specific online degrees from specific foreign institutions; neither Qatar nor Bahrain  accept online degrees or qualifications.

To strengthen the integrity of both the institutions offering fully online programs and the quality of the programs themselves, the Maritimes Provinces’ Higher Education Commission created institutional review and performance regime, coupled with program review for online learning, that supported the continuing operation of some private institutions based in the province (e.g. University of Fredericton, Yorkville University) and the closure of others (Meritus University and Lansbridge University). Similar regulations were also implemented in British Columbia, Alberta and Ontario. These organizations, together with other quality assurance agencies around the world (e.g. the United Arab Emirates, New Zealand, Australia, Brazil and across Asia) also developed revised standards and quality assurance requirements for public institutions offering online programs. Tony Bates lists quality assurance agencies around the world.

The concerns with quality and integrity of distance and online programs has led governments to focus on strengthening the approach to quality assurance taken by regulatory bodies. Examples of national initiatives include:

• The UK Quality Assurance Agency’s Guidelines on the Quality Assurance of Distance Learning 
• The Norwegian Association for Distance Education’s Quality Standards for Distance Education 
• The Australasian Council on Open, Distance and E-Learning’s benchmarks for DE and e-learning
•  The National Association of Distance and Open Education Organizations of South Africa’s quality criteria for designing and delivering distance education
•  The African Union Commission’s African Higher Education (including DE) Quality Rating Mechanism
• The European Association of Distance Teaching Universities Quality Manual for E-learning in Higher Education 
•  The Asian Association of Open Universities offers the AAOU Quality Assurance Statements of Best Practice
• The International Council for Open and Distance Education published the results of a pilot project to identify Regulatory Framework for Distance Education in the South West Pacific and South East Asia Region, to investigate the best practices, and to examine the rules and regulations hindering distance and online education development.

At the same time, a focus on learner mobility – a key driver of the European Union’s strategy for post-secondary education – has led to the development of a range of Transnational Qualifications Frameworks, which support open, flexible and transparent education, including distance and online education. One of the most comprehensive is the Transnational Qualification Framework for the Virtual University of the Small States of the Commonwealth. The European Training Foundation documented a range of such arrangements covering Europe, South Africa, Caribbean and Asia and the European Centre for Development and Vocational Training has provided a global inventory of such frameworks. New Zealand has also developed an effective, active and efficient framework. In each case, these frameworks establish the conditions under which a qualification (or part of a qualification) earned in one jurisdiction can be recognized in another.

There remains a series of issues, captured well in a book edited by Uvalić-Trumbić and Daniel (2013)[21]. The Council for Higher Education Accreditation (CHEA) has also issued a set of quality principles, which can be used to frame the issues associated with online learning. Of particular concern are issues of corruption – the integrity of admissions, teaching, learner assessments and examinations, for example.  A valuable collection of papers outlining these issues and potential responses to them has also been developed by CHEA.

Thinking about quality, accreditation and public assurance is changing, as this paper from Contact North | Contact Nord indicates. Regulators are constantly reviewing practice  to continuously improve learning outcomes and satisfy demand for public assurance. The policy shifts we are seeing relate to changing the agreed outcomes of higher education – e.g. enabling MOOCs for degrees, micro-credentials and a new focus on learner mobility.

4. The Use of Open Educational Resources

Policy Options:

• Licensing Policies: insert open licensing requirements into existing systems that create educational resources.
• Resource Policies: allocate resources directly to support OER.
• Inducement Policies: call for or incentivize actions to support OER.
• Framework Policies: create pathways or remove barriers for action to support OER.

Following the 2012 Paris UNESCO Declaration supporting the use of open educational resources (OER) as a means of increasing access to quality, affordable learning and as a mechanism for meeting the UN’s sustainable development goals, many jurisdictions have adopted policies, regulations or practices which enable the widespread use and adoption of OER. OER are defined as teaching, learning, and research resources that reside in the public domain or have been released under an intellectual property license that permits their free use or repurposing by others[22].

The focus of these policy developments are[23]:

• Licensing Policies: insert open licensing requirements into existing systems that create educational resources.
• Resource Policies: allocate resources directly to support OER.
• Inducement Policies: call for or incentivize actions to support OER.
• Framework Policies: create pathways or remove barriers for action to support OER.

The intention of such policies is generally to spur the development, adoption and use of OER while at the same time lowering the costs of higher education for learners. A 2014 review of these policies is available here, which provides background to the 2017 global review from the Commonwealth of Learning. National policy examples are available from Fiji, South Africa, across the global south and in Europe. Policy templates have also been developed to ease adoption – the UNESCO/Commonwealth of Learning templates are here. In Canada, a number of provinces are supporting specific OER initiatives. In Ontario, funds allocated to eCampusOntario are being used to support the development and use of OER textbooks and materials and a number of western Canadian provinces are partnering on an OER textbook initiative aimed at lowering the cost of higher education for learners.

5. Funding Policies with Respect to Both Learners and Institutions

Policy Options

• Block grants with a significant level of autonomy for the institutions in how they achieve agreed outcomes.
• Outcome-based funding based on student volumes and rates of progress.
• Differential funding for different disciplines within the system.
• Online learning treated no differently from other forms of learning in terms of student funding.

One barrier to innovation, institutional leaders will suggest, relates to the funding mechanisms for higher education. For example, moving from a limited number of admission start dates each year (e.g. the semester model) to start anytime requires a change in how funds flow to the institution. The Carnegie Unit – a number of hours of learning in class for a specific learning outcome leading to credit recognition and fund allocation by government – remains in use in a variety of jurisdictions around the world and inhibits innovation, especially in terms of online and flexible delivery. Even the Carnegie Foundation for the Advancement of Teaching suggests it is time to abandon this formulaic approach to funding and replace it with a more flexible, standards based learning outcomes approach.

Several jurisdictions do not use this approach. For example, Kentucky uses a three component model for funding its colleges and universities, which is provided as a block grant:

• 35% of allocated funds are based on completion rates for the programs offered by the institution.
• 35% of allocated funds relate to course completion (credit hours) at each campus.
• 30% of allocated funds reflect a base grant for operations, infrastructure and technology.

Known as a performance or outcomes funding model, other US jurisdictions are also exploring how to shift away from conventional funding models to funding based on performance and strategic intentions. Similar developments are also taking place in Europe and Australia.

In terms of online learning, the issue is whether this form of design, delivery and deployment is treated differently from more conventional forms of delivery in terms of funding. Many institutions charge online learners either a technology support fee or a distance learning fee (see here) to cover a range of supports over-and-above tuition. Others do not fund online learning in the same way as face-to-face learning. Yet others use funding mechanisms to actively promote registration and completions online – e.g. in 2014 the European Commission called for targeted funding within the emerging models to encourage and enable the growth of technology enabled learning, especially given the significant growth of online learning in Europe.

In some jurisdictions, tuition is free (Denmark, Finland, Germany, Iceland, Norway and Sweden). In the US, free tuition and the forgiveness of student debt are significant social policy issues, which divide political parties who see this issue as one of the role of government and the balance between public and private interests. Several jurisdictions have found ways of reducing or eliminating tuition for certain students, based on income (see here for an example).

6. Support and encouragement for institutional collaboration in teaching and learning.

Policy Options:

• The creation of delivery networks, such as Contact North | Contact Nord in Ontario or similar organizations in the US, such as the Great Plains Interactive Alliance (see a list of others  here).
• The creation of innovation and development networks, such as eCampus Ontario and BC Campus.
• Requiring credit transfer and block credit recognition, so as to enable learner mobility.
• Using funding as a means of requiring collaboration, with examples such as the Canadian Atlantic provinces enabling new approaches to apprenticeship in sixteen trades, leveraging  shard IT systems to support this work.
• Using capital grant allocations to facilitate university:college collaboration, as was done in Ontario between 1994-2000 and is now occurring in Alberta through the shared services initiatives.
• Supporting public/private partnerships for online learning.

There have been significant developments in college/university collaboration, especially in some jurisdictions – e.g. Florida, California, British Columbia, Alberta and Scotland. In each case, governments have both enabled and encouraged such developments, without necessarily making significant new financial investments.

Perhaps the most substantial collaboration in the world was facilitated by the Commonwealth of Learning in partnership with governments and institutions in the thirty-two small states of the Commonwealth. Institutions share resources, support joint projects, engage in capacity building and support transferability of credits and programs between their nations. Known as the Virtual University of the Small States of the Commonwealth (VUSSC), it represents a milestone achievement in collaboration for online learning.

There are growing examples of public institutions partnering with private organizations to deliver online learning. For example, the partnerships between many institutions and for-profit MOOC providers – Coursera (US), FutureLearn (UK), Udacity (US), XuetangX (China) – led to 54.4 million learners pursuing courses in 2017. Increasingly, many of these courses lead to some 289 micro-credentials, university or college degrees, diplomas, and other credentials.  Another example of such partnerships is that between colleges and universities and content providers. More than thirty colleges and universities partner with Pearson for content provision. Others have chosen to partner with McGraw Hill or other content providers. There are also online course “exchanges”, such as the Internet Course Exchange of the Western Interstate Commission on Higher Education (WICHE), where some licensing arrangements involve public and private players.

Technology sharing is also a component of some government investment. This is what is behind the Atlantic provinces investment in apprenticeship and a variety of jurisdictions have encouraged and enabled similar developments, such as the network of State University of New York institutions or Ontario’s Orion Network or Cybera in Alberta. These collaborations also extend to technology advice and information sharing through organizations like Educause in the US and JISC in the UK, both of which receive some of their funding from government.

7. Cybersecurity and Privacy of Data for Online Learners

Policy Options:

• Enhanced coordination across government, government agencies and government funded institutions to create common approaches to cybersecurity.
• Reinforced public-private cooperation.
• Improved international cooperation, for example in terms of the pursuit of cybercrime and data theft.
• Respect for the balance between privacy, security, innovation and freedom of expression.
• Sovereignty considerations – where does data reside and a concern with cloud-based storage of data and access to such data held in other jurisdictions.
• The economic costs of cybersecurity for security and risk management.

A key issue, made more pertinent by recent cyber security concerns and data breeches[24], is the security of digital information held about each learner. While cybersecurity has become a critical policy issue (see here and here), the key elements of such policies are:

• Enhanced coordination across government, government agencies and government funded institutions to create common approaches to cyber security (here).
• Reinforced public-private cooperation (here and here).
• Improved international cooperation, for example in terms of the pursuit of cybercrime and data theft (see here).
• Respect for the balance between privacy, security, innovation and freedom of expression.

Some emerging policy components include;

• Sovereignty considerations – where does data reside and a concern with cloud-based storage of data and access to such data held in other jurisdictions (e.g. the power of the US Homeland security legislation for data held on US servers).
• The economic costs of cyber security – security and risk management come with economic costs (see here). A 2010 Ponemon Institute “U.S. Cost of a Data Breach” report found that the average data breach cost companies $214 per compromised record and averaged $7.2 million per data breach event.

Student records, student interactions in an online environment (e.g. through a learner management system), social media use in online learning, student and teacher interactions, inappropriate online behaviour are all issues which are addressed both by institutional policies (some governments require all institutions to develop, review and publish such policies), and cross-institutional policies concerning data sharing and related risk management measures. Some governments have also required senior staff at institutions to undergo information security awareness training, intended to reduce risk and increase cyber security of student data.

The US organization Educause has significant resources to help both policy and practice development within and between institutions, as does JISC in the UK. Governments offices of Privacy Commissioners are also a source for guidance with respect to the legal requirements for cybersecurity (e.g. Ontario’s guidance is here).

Most Chief Technology Officers / Chief Information Officers of colleges and universities see this as a growing issue, made very clear by recent major data breeches. Governments are actively looking at ways of creating a policy, legal and regulatory environment to minimize risk and support innovative approaches to the pursuit of cybercrime.

8. Accountability and Key Performance Indicators (KPI’s) for Online Learning

Policy Options

• Develop specific indicators for the performance and growth of online learning.
• Benchmark institutions against others regionally and internationally
• Frameworks for accountability and public assurance.

A number of jurisdictions, especially those which have made significant investments in online learning, are seeking to justify that investments in terms of both learning outcomes and value for money. They require reporting on a variety of indicators, including (but not limited to):

• Number of courses developed against cost
• Time taken to develop each course
• Number of learners registered in each course
• Completion rates, including time to complete and level (grade) of completion
• Cost to deliver learning per online student compared to costs of a conventional student
• Learner satisfaction (and learner engagement) with their learning experience
• Strategic intentions of institutions with respect to online and blended learning – rate of anticipated growth, requirements for students to complete one or more online course as a requirement of their program, anticipated growth rates for online registrations.

Such indicators will only be effective if a nuanced approach to understanding online learning is followed. There is no one size fits all and there are a variety of forms, models and practices for online learning. On-campus technology-enhanced learning will look different and will have to be evaluated differently than a fully online, off-campus online course. While the elements measured may well be the same, each indicator will have a different meaning in these different online learning environments. This is the point made by Shale and Gomes (1998) and is reinforced by a wider analysis of the use of KPI’s in jurisdictions such as Ontario, Australia and New Zealand[25].

Some jurisdictions have encouraged their institutions to participate in the National Study of Student Engagement (NSSE), which is now an international study with institutions in Canada and other parts of the world participating alongside US institutions. However, the NSSE is designed for on-campus learning. Several researchers have developed new instruments or procedures for online student engagement (here, here and here).

International comparison and league tables of higher education performance based on specific criteria are available (e.g. here and here), but few focus specifically on online learning. There are some rankings for certain kinds of online programs: the Financial Times offers a ranking of online MBA programs and Times Higher Education of medical programs. Various other subjects are also ranked. The value of such rankings is the subject of frequent criticism from higher education leaders (here and here).

The policy issue here is accountability and public assurance. This is an evolving field of public policy in higher education in particular (for example, here and here). We can expect to see more developments which will require greater system-wide accountability and developments in institutional governance. Some jurisdictions have used system mandate agreements (here and here) to clarify roles and accountabilities.

Emerging Policy Opportunities and Directions

As governments focus on both the integrity of their higher education provisions and on the need to rapidly reskill the workforce in the face of emerging demographic shifts and emerging technologies, policy development needs to reflect these challenges. These include, but are not limited to:

• Shifting some investment from long programs to micro-credentials and modular, stackable learning. This links to the broader issue of the link between program investment and labour market needs, which is becoming a major issue in Europe (here).
• Supporting worker transition from “old” job roles to new work as employers seek to leverage the power of emerging technologies to increase productivity and competitiveness. The role of lifelong learning, online learning and MOOCs are a part of this conversation (here) as are the links to sustainable development (here).

• Managing the need for more effective and efficient systems of higher education. There are also a large number of institutions facing operational budget challenges. The challenge is to secure system effectiveness and efficiency.

• Leveraging technology investments to improve learning outcomes while managing the risks associated with cyber security and crime. It is clear that technology enhanced learning will grow and expand, especially given recent developments in artificial intelligence, digital translation and assessment. The challenge is to leverage this growth while managing the risks of cyber security and the concerns about the role of AI in society.

• Increasing collaboration, partnerships and alliances. New models for collaboration are emerging in higher education, enhanced by online learning, which blur lines between institutions, programs and credentials. The ability to embrace these and act quickly to implement them will provide new policy challenges.

• Responding to new forms of credentials, such as assessment only credentials (see here) and MOOC-based degrees (here).

• Recognizing, regulating and utilizing credential providing  global players, such as Purdue Global or FutureLearn as part of a systems strategy for higher education.

Policy issues, especially those focused on innovative approaches to teaching, learning and skills development, remain a lively domain for debate and action. Interestingly, the issue of legitimacy for online and blended learning has moved to what role does online learning play in a strategy for system growth and development.

We appear to be in an era of transition where practices are being challenged by technology, student demands and social needs. Yet the issues of access, quality, cost and value will dominate the policy space in the coming decade, just as they have done for the past fifty years. Online learning is an integral part of each of these issues and of the policy decisions made concerning them.

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April 2018