Course Repetition and Repeatability – Legal Mandate and Significant Change in Industry or Licensure Standards: Sharing the Burden for Certifying the Need for Repetition
Today, industry standards are changing at an unprecedented pace, especially in areas such as technology and transportation. As such, colleges and districts that provide the courses and training for students to work in industry must be responsive to these changes. Course and program offerings must keep pace, including course offerings that meet a legal mandate or address a significant change in industry or licensure standards. This point is where the discussion continues on course repetition and repeatability.
In July of 2011, the California Community Colleges Board of Governors, through the consultative process, approved a series of changes to Title 5 Regulations pertaining to course repetition and repeatability. Prior to 2011, some critics claimed that students could re-enroll in courses with no limit. Limits did actually exist, but they were broad and permissive and were viewed by many in the public as misuse of taxpayer dollars. In November of 2013, the California Community Colleges Chancellor’s Office published Credit Course Repetition Guidelines to provide guidance to colleges and districts for course repetition and repeatable courses. In short, course repetition and repeatability were reined in by the Title 5 Regulation modifications in 2011.
In Title 5 §55000, “course repetition” is defined as when a student who has previously received an evaluative symbol in a credit course, as set forth in Title 5 §55023, re-enrolls in that course and receives another evaluative symbol. Title 5 §55041 provides that courses may be listed as “repeatable” for only three reasons: intercollegiate athletics, courses that are required by the CSU or UC to be repeated for a major, and vocational and academic competition courses. In addition, numerous situations are defined in which a college or district may permit a student to petition to repeat any course. Two of these situations are especially relevant to industry:
- the course is determined to be legally mandated. “’Courses that are determined to be legally mandated’ are courses that are required by statute or regulation as a condition of the student’s paid or volunteer employment” (Title 5 §55000 (k)).
- as a result of a significant change in industry or licensure standards, repetition of the course is necessary for the student’s employment or licensure (Title 5 §55040 (b) (9)).
In both cases, such courses may be repeated for credit any number of times. The governing board of the district may establish policies and procedures requiring students to certify or document that course repetition is legally mandated or a significant change in industry or licensure standards necessitates course repetition. However, whether or not the district places responsibility on the student for providing verification of the legal mandate or the change in industry or licensure standards, the district is ultimately responsible for establishing and maintaining documentation of the mandate or the change in the event of an audit.
The criteria in Title 5 regarding when courses may be deemed “repeatable” or the conditions under which students are permitted to repeat a course is in reference to colleges or districts receiving apportionment for the enrollments. Colleges and districts may permit students to repeat courses beyond the limits set forth in Title 5 §58161 provided that the college or district is not claiming apportionment.
Questions and concerns regarding course repetition have continued to surface even though more than five years have passed since the guidelines were published. While many of the issues have been addressed, questions remain about who should carry the burden to provide documentation supporting a legal mandate or a significant change in industry or licensure standards necessitating course repetition. Colleges and districts must be cognizant of and follow the law, yet they should not place the burden solely upon the student, inadvertently pushing students away who may meet the criteria to repeat such courses. Students often need guidance and assistance as to what documentation is required and where to obtain the documentation, possibly some sample documentation that can meet the criteria, and a reasonable timeline to obtain the documentation. Students often abandon an advancement opportunity because accessing the opportunity appears insurmountable.
SHARING THE BURDEN
In the Chancellor’s California Community Colleges Vision for Success, the first two of the seven core commitments are as follows:
- Focus relentlessly on students’ end goals. “Getting students to their individual educational goals—whether a degree, certificate, transfer, or specific skill set—should be the explicit focus of the CCCs. More than just offering courses, colleges need to be offering pathways to specific outcomes and providing supports for students to stay on those paths until completion.”
- Always design and decide with the student in mind.
“Colleges need to make it easy for all students, including working adults, to access the courses and services they need. Students should not bear the burden of misaligned policies between education systems” (Vision for Success P.3).
These two core commitments make clear that the Chancellor’s Office fully supports the idea that colleges and districts should help students take the courses that the students need, whether for a specific skill set or access to a course. Faculty, administrators, professional staff, and students should work with their district governing boards to establish or revise local policies and procedures for acquiring the necessary and sufficient documentation to allow necessary course repetition. Furthermore, the college or district may consider incorporating some of the following as they meet their goals for the Vision for Success:
- Faculty should provide their curriculum chairs, counseling colleagues, department chairs, and deans with a list of the courses that students may be eligible to repeat;
- Faculty, administrators, and professional staff can create guidance documents to accompany those courses that may qualify for some students to repeat; and
- Departments and counseling offices can maintain a repository of employers, boards, and agencies that have verified criteria for necessary course repetition and provide students with sample documents that have met the criteria for such course repetition.
Not all students will meet the criteria to repeat courses as a legal mandate or a significant change in industry or licensure standards. However, processes should be in place through which colleges and districts can work with those students that believe they may meet such criteria in order to ascertain whether or not the students’ situations fall within the parameters of the law and then access the appropriate and clearly defined documentation within a reasonable timeline. As colleges and districts hold the final responsibility for documenting the need for course repetition, they should share the burden with the students and provide guidance to certify the need for repeating a course.
1. The document Credit Course Repetition Guidelines is available at https://extranet.cccco.edu/Portals/1/AA/Credit/2013Files/CreditCourseRep...
2. For background on the issues that surrounded the course repetition and repeatability debate, see Morse, Bruno, and Hillman, “The Concept of Credit Courses: Another Look at Course Repetition and Repeatability” in the September 2014 issue of the Rostrum, available at https://asccc.org/content/concept-credit-courses-another-look-course-rep....
3. The Vision for Success is available at http://californiacommunitycolleges.cccco.edu/portals/0/reports/vision-fo...
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