This letter has been endorsed by the following faculty groups: the California Faculty Association, the Faculty Association of California Community Colleges, the California Community College Independents, the California Federation of Teachers, the California Teachers Association, the California School Employees Association, the California Labor Federation, SEIU California, and USW 5810.

April 18, 2013

The Honorable Darrell Steinberg

President Pro Tem

California State Senate

State Capitol, Room 205

Sacramento, California 95814-4900

SUBJECT:    SB 520 (Steinberg) as amended on April 17, 2013

POSITION:   Oppose

Dear Senator Steinberg:

On behalf of the faculty, staff and labor organizations of the University of California (UC), California State University (CSU) and California Community Colleges (CCC) representing the 145 public higher education institutions in California, we write to express our strong opposition to SB 520. While we appreciate the opportunity to have an open dialogue about our concerns regarding SB 520 and the adoption of your recent amendments, we remain opposed to this measure for several important reasons.

As constituents and stakeholders of California’s three higher education segments, we care deeply about access to quality higher education. Many of us teach, provide support services for and/or take online courses and know firsthand that increasing online courses is not a panacea. In fact, we believe that SB 520 as amended will lower academic standards, exacerbate the educational divide along socio-economic lines and diminish accountability within our institutions. Ultimately, we believe SB 520 would worsen the situation it attempts to address.

Educational Quality:

Faculty in discrete disciplines are instrumental in determining which courses are appropriate for online instruction, the development of curricula, and ensuring ongoing quality through a rigorous regular institutional review processes in each of the three segments.

SB 520 would require the California Online Student Access Platform (COSAP) to develop a list of 50 most impacted lower division courses through a mandated public- private partnership. Requiring faculty to approve a specified number of courses developed with private providers hinders the ability of faculty to exercise their best judgment and to approve only those courses that merit approval.

Impact on Students:

The Legislative Analyst’s Office found that online course completion rates are substantially lower than face-to-face community college courses. Research has demonstrated that online courses are not as effective for lower division students, underprepared students, or lower income students. Targeting lower division courses for online delivery puts at-risk students at still greater risk for failure rather than facilitating their access to academic success. Further, a recent large-scale study by Columbia University concluded that online courses exacerbate the ethnic minority performance gap.

It is also true that all three segments have successfully provided a significant number of online courses, created and taught by their own faculty members. These courses are designed for the students we teach and crafted to ensure maximal opportunity for student success.

The best way for the Legislature to ensure that college students can take the courses they need to graduate on time would be to increase funding to its public colleges and universities to ensure there are enough seats in classes students need.

Contracting-Out : Turning Over Public Education to Untested Private Companies:

Years of devastating budget cuts have starved California’s public higher education institutions and they are now being held responsible for their inability to meet the demand for higher education – one of the consequences of those cuts. Although it may not be the author’s intent, SB 520 would lead to the contacting out of instruction and student support services.

There is no evidence that SB 520 would increase access. More likely, this proposal would simply shift public dollars used to fund traditional class instruction to administrative costs and private companies that are seeking a revenue model for their courses and technology services.

Currently, the development and the instruction of online courses have been in accordance with local collective bargaining contracts in order to serve the needs of students. While California’s public colleges and universities are held accountable to the taxpayers, the provisions in SB 520 depend on the private sector, which is not remotely accountable to the public, for Massive Open Online Courses (MOOCs) that will not meet the needs of California’s students. While SB 520 proposes faculty input through the “sponsorship” of providing a course, no clear definition is provided to understand what it means to “sponsor” a MOOC.

Education researchers have yet to determine why a vast majority of students fail to complete MOOCs offered by private vendors and there has been no discussion of accountability measures to ensure success and quality education when instruction is contracted out as proposed in SB 520. We have serious concerns that requiring faculty senates to authorize private vendors to offer courses in our institutions through the use of their platforms could seriously damage our reputation and jeopardize our accreditations.

Although we share your commitment to providing access to higher education to California’s residents as envisioned in the Master Plan, we have serious concerns that SB 520 as currently envisioned will undermine existing and well-established quality control processes in the three segments of California higher education.  We support the goal of increasing access to public higher education, but students must have access to courses that match their instructional needs. Empirical evidence demonstrates that the wholesale expansion of online courses—especially lower division courses—is not the most effective or efficient way to achieve this goal. For these reasons, we must respectfully oppose SB 520.