Student Identity Verification in Distance Learning Policy

Purpose:

The federal Higher Education Opportunity Act (HEOA) requires that colleges and universities offering for-credit distance education courses or programs have processes in place to ensure that the student registering for a course is the same student who participates in the course or receives course credit. Compliance with this policy ensures the University’s ability to distribute federal financial aid.

This policy applies to all credit-bearing distance courses offered by Willamette University.

Definitions Related to this Policy:

Distance Education means “education that uses one or more of the following technologies to deliver instruction to students who are separated from the instructor or instructors and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.” (34 CFR 600.02). The technologies that may be used to offer distance education include:

• The internet;

• One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
• Audio conference; or
• Other media used in a course in conjunction with any of the technologies listed above.

Learning Management System (LMS) means a software application used to manage and deliver educational programs, facilitate course delivery and management, and track student progress.

Substantive Interaction means that which engages students in teaching, learning, and assessment consistent with the content under discussion, and includes at least two of the following:

• Providing direct instruction;
• Assessing or providing feedback on a student’s coursework;
• Providing information or responding to questions about the content of a course or competency;
• Facilitating a group discussion regarding the content of a course or competency; or
• Other instructional activities approved by the institution’s or program’s accrediting agency

Policy:

1. Secure Student Identification Procedures
   1. At the time of admission, students are assigned a unique Student ID that is matched with each students’ demographic data and then housed in Willamette’s applicant status portal.
   2. Willamette’s Integrated Technology office assigns each Student ID a unique username, and students use this username to create a password to log into Willamette’s various online portals, including Willamette’s LMS. When establishing this account, students are required to agree to the University’s Responsible Use of Information Technology Resources policy, which outlines their responsibilities for providing their complete and true identity information in any identification verification process.
   3. The Registrar’s Office adds students to their various course sites via Willamette’s LMS, and students use this LMS to connect to any Distance Education course. Students also submit assignments, participate in discussions, and view their grades through the LMS.
2. Protecting Student Privacy
   1. Willamette University upholds the provisions of the Family Educational Rights and Privacy Act (FERPA). This federal law protects the privacy of student information, including students engaged in Distance Education, by requiring, with certain limited exceptions, that the student’s written consent be obtained prior to disclosing any personally identifiable information in the student’s education records.
   2. Personally-identifiable information collected by the university may be used, at the discretion of the institution and in compliance with applicable state and federal laws, as the basis for identity verification. For instance, a student requesting that their LMS password be reset may be asked to provide two or more pieces of information for comparison with data on file, or may be subject to further identity verification through Willamette Information Technology procedures.
   3. Faculty teaching courses through Distance Education methods must ensure that their individual courses comply with the provisions of this policy. Faculty must inform the Registrar’s Office of any new technologies being used to verify student identity, so that published information on student privacy can be maintained appropriately, and so that the University can coordinate resources and services efficiently.
3. Substantive Interaction in Distance Education
   1. In accordance with Federal Guidelines 34 CFR 600.2, Distance Education courses at Willamette University will include two or more of the following Substantive Interactions:
      • direct instruction;
      • assessment or feedback on a student’s coursework;
      • information and responses to questions about the content of the course; and/or
      • group discussion regarding the content of the course.
   2. If a student does not experience two or more of these Substantive Interactions in their Distance Education coursework, they should submit a complaint to Willamette University’s Registrar’s Office. Complaints that cannot be resolved through Willamette’s internal processes may be submitted to National Council for State Authorization Reciprocity Agreements (NC-SARA) or to the Northwest Commission on Colleges and Universities (NWCCU) in accordance with their policy on Complaints Regarding Member or Candidate Institutions.
4. Fees Related to Student Identity Verification - At this time there are no additional student fees associated with student verification. In the event any verification fee is needed, it will be posted on the course registration site to provide an advance alert to students.

Effective Date: June 18, 2025
Responsible Person/Primary Contact: Assistant Provost of Academic Planning and Accreditation
Responsible University Office: Academic Affairs