Public Testimony on College Credit Plus Rules
Ohio Department of Higher Education
December 29, 2015

Thank you for the opportunity to provide comments on the amended and new rules for College Credit Plus (CCP) that were filed with JCARR on November 24, 2015. My name is Tom Walsh, Vice President of the Ohio Association of Community Colleges. OACC, which represents all 23 of Ohio’s public community colleges, respectfully requests revising the proposed rules to address the concerns that have been identified by our colleges outlined below. These suggested recommendations would alleviate what we believe could be cumbersome administrative burdens while ensuring maximum student participation in this important dual enrollment program.

3333-1-65 Definitions

  • Proposed 3333-1-65 (D) expands the definition of “fees” to include all supplemental and material costs that are not tuition. Expanding the definition of fees to include materials beyond a charge paid to the college is likely inconsistent with current statutory definition of tuition and fees charged for postsecondary enrollment. There are courses in which a student, whether CCP or non-CCP, may be responsible for supplies, materials and tools which the students are responsible to purchase. Often times, these materials, supplies or items are purchased from a third party and are not part of the college’s tuition and fee bill.

OACC recommends maintaining the current definition of “fee” under 3333-1-65 (D) and removing the proposed expanded definition.

3333-1-65.1 Notice to students regarding program opportunities

  • Proposed 3333-1-61.1 (A)(2) would require that all CCP information session be held from October 1st through January 15th. OACC believes that the deadline for these annual information sessions deadline is too early — particularly considering the Holidays and corresponding winter breaks would leave very little time to meet the deadline. Extending the deadline to the end of February will still provide ample time for the student to sign letter of intent to participate (April 1), for the secondary schools to finalize their master schedules and for the IHEs to complete any necessary enrollment requirements.

OACC strongly recommends that the date be changed to February 28 to hold the required annual information sessions.
3333-1-65.7 Procedures for an IHE receiving payment

  • Amended 3333-1-65.7 unfortunately does not address the SSID concerns that have been raised by IHEs regarding the fact that there are too many students participating in CCP that need to obtain their SSID number. This requires colleges and/or high schools to spend an excessive
    amount of time helping students acquire their SSID. In order to alleviate these administrative burdens, there must be improvements to the process to obtaining SSID numbers, requiring improved collaboration between the State, the secondary schools and IHEs. An improved process could help address many of the issues that we have identified with this process including: public high schools are currently not required to publish SSIDs on their transcripts, middle or junior high schools generally do not include SSIDs on their report cards while most middle or junior high schools do not even have transcripts.

OACC requests that ODHE and ODE help find a solution to access the SSID more easily. If it cannot be addressed in these rules, then we would recommend convening stakeholders in the near future to address these concerns.
3333-1.65.8 Allocation for nonpublic students

  • OACC is concerned with the new definition of “allocation unit” under amended 3333-1-65.8 (A)(1). The new unit allocation of no more than four credit hours means these students will be unable to take most upper-level courses and most math and science courses through CCP. This will essentially prevent nonpublic students to complete a sequence and is a significant barrier for partner schools who want to build robust CCP programs.

OACC recommends maintaining the current definition of “Allocation Unit,” as we believe the proposed cap of no more than 4 credit hours creates undue barriers for nonpublic students.

  • Recognizing sufficient State funding remains a concern for these students, a potential solution would be to allow IHEs the flexibility to charge unfunded nonpublic/home instructed l students a lower MOU rate without having to go through a waiver process. It seems unfair to require we go back to the higher rates with these students simply because the State was unable to fund them. By allowing greater flexibility, it would help provide dual enrollment pathways that are more attractive and beneficial for beneficial to nonpublic students compared to the proposed 4 credit hour maximum and would partially alleviate frustration amongst our nonpublic partner schools.

OACC recommends providing IHEs greater flexibility for nonpublic or home instructed students to increase opportunities for these students in light of funding/cost considerations.
3333-1-65.11 College Credit Plus Summer Term Eligibility

  • Proposed 3333-1-65.11 contains several eligibility criteria for Summer term that is inconsistent with CCP participation requirements for Fall and Spring terms. It is unclear why eligibility for students enrolling in Summer classes should be treated differently than those enrolling in Fall or Spring terms.
    • Tracking of Grades: Proposed 3333-1-65.11 (A) states that a student that is failing a course at the high school or IHE is ineligible to participate in Summer CCP. This requirement will create several administrative burdens on both the school and IHEs and raises several questions:
      • Who will track students’ grades?
      • Will HS guidance counselors be required to monitor all HS courses and will faculty have to report grades during the middle of the term?
      • What is the point during the Spring term that schools should use to determine whether the student is eligible? Would colleges have to determine eligibility when registration has opened (late March)? When the student has an advising appointment in February?
      • How should schools and colleges account for fluctuation in grades over the course of a term? For example, a college could check for passing grade in early April, but two weeks later a student’s grade could change drastically if they missed an assignment or failed an exam.
      • What would the process be for reporting grades midway through a term? While we understand the reasons for tracking a student’s progress, with thousands of CCP students enrolled in our colleges, this will place significant additional administrative burdens on both schools and IHEs.

In order to be consistent with Fall and Spring CCP eligibility requirements, OACC recommends eliminating this proposed eligibility prohibition.

If ODHE intends to maintain this requirement, it is essential that more direction be provided to address many of the questions raised above regarding timing, tracking and defining what is a “failing grade”, etc. Otherwise, this new rule will provide a great deal of confusion, inconsistent application and administrative confusion among participating institutions.

  • Prior Enrollment for Nonpublic Students: Proposed 3333-1-65 (B) would require a nonpublic school student to have been previously enrolled in a CCP course in order to be eligible for Summer term. As with (A) above, this requirement is inconsistent with eligibility for both Fall and Spring terms. It is unclear why eligibility for nonpublic students should be based on having participated in CCP during the previous academic year. Why should a student be prohibited from participating simply because they did not take a CCP course the year before? There are a number of reasons students may not be able to participate (scheduling, transportation, etc.) so preventing them taking advantage of Summer CCP seems unfair to the student. From a policy perspective, OACC believes this creates unfair barriers for nonpublic students that wish to accelerate their time to a degree.

OACC recommends eliminating the eligibility limitations for nonpublic school students under 3333-1-65.11 (B).

Once again, thank you for the opportunity to provide comments on the proposed College Credit Plus rules. OACC remains a strong supporter and partner in the CCP program and we appreciate your consideration of the issues and recommendations identified above.