Compliance as a University Wide (Enterprise) Issue

220x146-Regulation-Task-Force-ReportThe compliance problem is exacerbated by the sheer volume of mandates—approximately 2,000 pages of text—and the reality that the Department of Education issues official guidance to amend or clarify its rules at a rate of more than one document per work day. As a result, colleges and universities find themselves enmeshed in a jungle of red tape, facing rules that are often confusing and difficult to comply with. They must allocate resources to compliance that would be better applied to student education, safety, and innovation in instructional delivery. Clearly, a better approach is needed. Source: Recalibrating Regulation of Colleges and Universities

Every higher education administrator needs an introduction to compliance as an Enterprise (Institution Wide) Issue. Beware, entering the maze of rules, regulations, and requirements, is not for the faint of heart. It is complex, convoluted and confusing, and difficult to reconcile from the internal perspective of academic management as the lens most administrators rely upon. I recommend beginning with the 144 page report Recalibrating Regulation of Colleges and Universities cited in the opening quote and published by the Task Force on Federal Regulation of Higher Education (February 2015). Specifically, focus upon Appendix I, the Regulations Matrix (pages 43-57). This first matrix introduces the issues within a recognizable and approachable context of the issues related to the challenge of compliance as faced by front line administrators and institutional governance.

cover_trusteesdhip_julaug_13_0I recommend you next turn to the Board’s Role in the Regulatory Era available from AGB (Association of Governing Boards). If you are a member of a governing board then this is a must read. The succinct article is valuable to all administrators and those in academic governance as a means of building a cohesive awareness, understanding the scope and magnitude of the influence of a compliance culture on managing an institution. AGB just released a new publication Top 10 Campus Legal Issues for Boards that zeroes in on a finite list of legal risks that help campus citizens to understand that the issues of compliance may also expose the institution to legal and financial risks. AGB’s short list of issues includes:

  1. Sexual Violence
  2. Risky Student Behavior
  3. Cybersecurity
  4. Online Learning
  5. Affirmative Action In Admissions and Financial Aid
  6. Workplace Issues
  7. Statutory and Regulatory Compliance Issues
  8. Federal Cost Accounting and Effort Reporting
  9. Construction and Deferred Maintenance
  10. Transparency, Ethical Conduct, and Behavior

If you have specific compliance concerns, findings, or wish to dig deeper then I recommend turning to the Higher Education Compliance Alliance (HECA) Compliance Matrix which provides a comprehensive list of key federal laws and regulations governing colleges and universities. It includes a brief summary of each law, applicable reporting deadlines, and links to additional resources.

If you wish to explore a career in compliance then I recommend the National Association of College and University Attorneys (NACUA) and the University Risk Management and Insurance Association (URMIA).

If you have other resources you recommend please feel free to append them to this post.




Future Proofing Your Strategic Plan, January 2016



January 20-22, 2016, Claremont California

The design of the Institute for Future Proofing Your Strategic Plan, 2016 recognizes that strategic plans developed under a 20th century paradigm and context do not adequately prepare institutions for the realities of the emerging global digital learning ecosystem.

Eventbrite - Institute for Academic Strategic Enrollment Management and Sustainability

There is mounting evidence that the condition of higher education grows more ominous. (Higher Education: Apocalypse Now?) One thing has become crystal clear — no more business or planning as usual. The Institute focuses upon the process of Future Proofing a Strategic Plan, detailing 10 vital planning initiatives required to prepare for the future to achieve fiscal and enrollment sustainability.

  1. Future Proof your Strategic Plan (The Importance of a Prototype and how to do one quickly)
  2. Revitalize the Academic Master Plan
  3. Engage Academic SEM Integrated Planning
  4. Develop and Implement Academic Program SEM Initiatives
  5. Revitalize CORE/GE Curriculum
  6. Refocus and enhance Strategic Position Strategies
  7. Optimize Resources
  8. Develop Capacity
  9. Solidify an Institutional Effectiveness System to Inculcate an Integrated IE Quality Culture
  10. Accelerate action, make room for the work

Academic leaders must plan to meet the challenges and opportunities of higher education as it is carried into the future by the paradigm shift to a global digital learning ecosystem. Without a Strategic Plan and Master Academic Plan that are aligned with future realities, institutions are powerless to forging near, mid, and long term strategies for enrollment and fiscal health of colleges, schools and programs.

Who Should Attend

The Institute is designed for institutional and academic leaders, including board members, presidents, provosts, vice presidents, deans, department chairs, faculty leaders, academic governance officers, interested faculty, accreditation team members, institutional planners, and institutional effectiveness professionals.

Session Summaries

  • Session I: Understanding the emerging global digital learning ecosystem
    The first session opens with building an understanding of the emergence of the digital learning ecosystem and the changes to the rules in education and learning it brings. A survey of the overall changes, the rules and sectors they disrupt and the emerging principles that govern the future will be covered.
  • Session II: Future Proofing Your Strategic Plan
    We begin with the importance of developing a Prototype Strategic Plan as a means of shifting dialog to  framing the future rather than focusing upon the discomfort of change or the disruptions of current or past dynamics. Then we will provide a method to do one quickly.
  • Session III: Academic Master Plan for the New Learning Paradigm
    This session focuses upon the Academic Master Plan (AMP) or as some like to call it a Master Academic Plan (MAP). The AMP is critical to the future because it establishes all of the basic elements of the curriculum’s architecture. It is in the Academic Master Plan where the foundations for the future are established. This session assesses the strengths, weaknesses, opportunities and threats emanating from the degree of alignment between architecture, program design, course options, assessment strategies, and curriculum-learner optimization pathways. Particular attention is paid to creating strategic advantage through curriculum architecture revitalization.
  • Session IV: Establishing and Optimization Curricular Value for Market Advantage
    Examines the principles of sustainability and applies them to various curricular scenarios (such as revitalization of the core or general education curriculum, establishing community of practice based programs of study…). Focuses on innovating from where you are with what you have. Emphasis is identifying opportunities and focused implementation.
  • Session V: Understanding Academic and Enrollment Strategies Tactics and Capacities
    Examines basic principles of effective enrollment management, the fit and friction points encountered in academic SEM collaboration. Introduces the tyranny or the synergy of the link, or lack thereof, between academic and SEM calendars and cycles.
  • Session VI: The Academic SEM Plan
    Evaluates and constructs the principles of integrating the Academic Master Plan with the Strategic Enrollment Management Plan.
  • Session VII: Securing a Strategic Position in the Global Learning Marketplace
    This session focuses upon the assessment of strategic position as informed through six lenses.
  • Session VIII: Optimizing Performance and Institutional Effectiveness
    Examines basic principles of establishing a comprehensive and cohesive system for institutional effectiveness. Identifying and defining capacity requirements and managing workflows and cycles to maximize fiscal and enrollment health.

Eventbrite - Institute for Academic Strategic Enrollment Management and Sustainability

Join us at one or more of our Institutes to more deeply explore critical issues facing higher education and strategies to address them.

Academic SEM Posters Now Available

Academic SEM Funnel [MGDA01]


Academic SEM Cycles [MGDA02]





Understanding Accumulated Student Debt, Rising Tuition, Public Policy

ASDThe impact of accumulated debt on federal financial aid policy/funding, state financing of higher education, institutional enrollment strategies, and student college going decisions is complex and difficult to unravel. The New York Federal Reserve Bank has released a staff report contributing to the understanding of the complex intertwined dynamics that deserves a thorough read and discussion at the institutional strategy level. I have some issues with causal inference and conclusions but the issue is of paramount importance. There are significant implications and ramifications to their findings. I have selected a couple of resources that help focus the dialog on strategic issues.

Consider the finding “We find that institutions more exposed to changes in the subsidized federal loan program increased their tuition disproportionately around these policy changes, with a sizable pass-through effect on tuition of about 65 percent.”

  • What does this actually mean? Does it infer that institutions’ adjusted tuition is based upon aid formulas rather than true labor and compliance costs? How does this play across sectors, types, regions and states? What are the political ramifications of this finding and what will happen in the hands of politicians in a national election cycle?

Consider the data published in the Chronicle of Higher Education that indicates “just 20 universities are responsible for a huge share of graduate-student debt, amounting to more than $6.5 billion in a single year (2013-14).” and goes onto show that Walden University ranked first with $756,336,024 in graduate student debt. (Walden U. Responds to Report on Graduate-Student Debt)

  • Billions spread over 20 institutions gets everyone’s attention. Is this an expose on exploitive strategy or does the data need to be contextualized? Contextualizing the data is something that needs to be done more adroitly by the higher education community. Again what are the implications and political fall out?

Consider the intensifying focus on the earnings to accumulated debt ratios being examined at the programmatic level as examined in the Brookings study included below.

  • The emergence of the relationship between debt, funding and earnings will intensify. The rate of return and schedule of payback, the value to society not just the individual will be asked again and again, and the focus on outcomes will become more intense and more heated.

The New York Federal Reserve Bank in their July 2015 Staff Report examines the

Credit Supply and the Rise in College Tuition: Evidence from the Expansion in Federal Student Aid Programs

 When students fund their education through loans, changes in student borrowing and tuition are interlinked. Higher tuition costs raise loan demand, but loan supply also affects equilibrium tuition costs—for example, by relaxing students’ funding constraints. To resolve this simultaneity problem, we exploit detailed student-level financial data and changes in federal student aid programs to identify the impact of increased student loan funding on tuition. We find that institutions more exposed to changes in the subsidized federal loan program increased their tuition disproportionately around these policy changes, with a sizable pass-through effect on tuition of about 65 percent. We also find that Pell Grant aid and the unsubsidized federal loan program have pass-through effects on tuition, although these are economically and statistically not as strong. The subsidized loan effect on tuition is most pronounced for expensive, private institutions that are somewhat, but not among the most, selective.

Huffington Post published the Average Student Debt Burden In Each State

Published data from the Department of Education, College Board, and The Institute for College Access & Success bringing student debt burden to the state level.

The Chronicle of Higher Education Reported “As Graduate-Student Debt Booms, Just a Few Colleges Are Largely Responsible

Published data focused upon graduate student debt burden as a separate issue. According to their table just 20 universities are responsible for a huge share of graduate-student debt, amounting to more than $6.5 billion in a single year (2013-14). Walden University ranked first with $756,336,024 in graduate student debt.

Brookings Reported in November 2014 an analysis of Graduates’ Earnings Growth and Debt Repayment

Brookings published an analysis of accumulated debt ratios for students enrolled in specific program types. The report also provides an interactive feature, Undergraduate Student Loan Calculator, to calculate the share of earnings necessary to service traditional loan repayment for 80 majors.

In closing

The relationships between accumulated student debt, graduates earning potential,  the earning to payback cycle alignment, and managing tuition price and discounting ratios, form a major issue stream that weighs heavily on the future of higher education. Institutions who understand this will focus on embedding as much value in their curricula as can be achieved. Then they will create a value narrative to guide implementation and align their institutional effectiveness model to close the loop and provide evidence of value. The context involved in achieving a higher value narrative requires we recognize the paradigm shift now underway. To align with the paradigm shift we must examine ways to future proof strategies within the broader context of how higher education is evolving.

Join us at one or more of our Institutes to more deeply explore critical issues facing higher education and strategies to address them.