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It’s time for some follow-up items from previous coverage.

Calbright College Crossroads

Calbright College is the fully-online competency-based California Community College launched in 2017. I have covered this story at e-Literate, PhilOnEdTech, and here at On EdTech over the years, and in general I have been critical of the original assumptions, the initial leadership, and the initial course design. I also noted the improvement in management and somewhat reset expectations from 2021.

This week the Legislative Analyst Office (LAO) gave a report on Governor Newsom’s proposed 2026-27 budget as it relates to the community colleges, including his proposal to increase ongoing Calbright funding from $15 million / year to $53 million / year. That is a major increase. The question is whether Calbright has shown enough progress to justify it.

While Calbright did not forecast enrollments in its original plans, it did plan for 22,400 job placements from its programs by the end of year 7 (Summer 2026). I called out in 2017 what I thought was a more reasonable estimate based on enrollments, not completions or job placements.

Calbright is in striking distance of the Phil Hill plan (another two full years at current growth rates would get them there). However, the completion rates are currently 13.6 percent based on its accreditor’s metrics, and the 22,400 plan is unreachable—Calbright might hit 1/10 of that goal.

Note the improved performance since the 2021 leadership change, which goes well beyond a Covid bump. Also note that Calbright is serving student populations in targeted age groups (working adults, older than 24) at greater rates than the overall system.

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The Reimagining and Improving Student Education (RISE) rules focusing on new student loan limits and related repayment and proration rules are in the final stage before a scheduled July 1st implementation date. OBBB was passed into law in July 2025 with requirements for July 1, 2026 implementation, which overrode the master calendar and is shockingly fast.

After the RISE committee reached consensus last fall, the Department of Education (ED) published the Notice of Proposed Rule Making (NPRM) at end of January, allowing 30 days of public comments. More than 75,000 public comments were submitted, and roughly 18,900 of these comments have been posted as of this morning. The final step is for ED to interpret and react to the comments and then publish the final rules.

The lobbying in the media and public statements has been intense lately, which is correlated with the huge number of comments. For On EdTech+ readers, I’d like to go deeper than what we have seen in the media thus far and give some insight into what might change (or not).

Note: I used NotebookLM, Gemini, Grok, ChatGPT, and Claude to help with this analysis. If you thought that I read all 18,900 comments and coded them, well, that would be incorrect.

Summary of the Comments

The overall sentiment from the public comments regarding the proposed Reimagining and Improving Student Education (RISE) rules is overwhelmingly against the measure. The vast majority of commenters express deep concern over the proposal to classify advanced healthcare and public service degrees—including advanced practice nursing (such as CRNAs and NPs), physical therapy, physician assistant studies, social work, public health, and mental health counseling—as "graduate" rather than "professional" degrees. Commenters argue that this narrow classification—only expanding from 10 to 11 degrees— and the resulting reduction in federal student loan limits, fails to recognize the clinical rigor, specialized training, and immediate licensure requirements of these programs.

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Four and a half years after Anthology acquired Blackboard, and 14 months after its debt crisis became visible, Blackboard has re-emerged from bankruptcy as a standalone EdTech company. The five-month Chapter 11 process unfolded largely according to plan, with only a one-month delay, a notable outcome given the complexity of untangling the combined company and restructuring ownership.

Court filings and company statements show a fundamentally reset organization: virtually no debt, $70 million in new financing, and Matt Pittinsky set to return as CEO once his non-compete and NDA obligations with competitor Instructure expire.

You can read the official announcements elsewhere. Here, we’ll focus on what actually matters—where Blackboard stands now and what signals to watch as the LMS market enters its next phase.

How We Got Here - A Recap and Update

Over the past 14 months, On EdTech readers have watched this saga unfold in real time—from early warnings about financial strain, to sponsor positioning in the debt process, to identifying Nexus and Oaktree as key players, to flagging the likelihood of a Pittinsky return. This week’s emergence confirms that trajectory.

• January–March 2025: Anthology missed a December 2024 debt payment while maintaining upbeat messaging. Coverage here highlighted the widening gap between PR tone and debt reality, and the growing likelihood of creditor control—even if handled out of court.

• April–September 2025: Veritas effectively exited. Distressed investors entered. I named Nexus and Oaktree in July. Competing buyers reviewed the books, but no deal avoided bankruptcy. The process ultimately led to the Ellucian and Encoura stalking-horse bids.

• Summer 2025: As I described in several posts, podcasts, and interviews, there has been an increase in university LMS evaluations that are driven by concerns over Anthology’s finances.

• Fall 2025: Nexus and Oaktree were effectively steering outcomes as controlling creditors, and the company entered bankruptcy at the end of September. The Day 1 plan was for 1) Anthology to sell off its non-teaching-and-learning / LMS assets to Ellucian for $70 million (CRM, ERP, enterprise business) and to Encoura for $50 million (lifecycle engagement and student success).

• Late Fall 2025: Matt Pittinsky, co-founder of Blackboard and then CEO of Parchment, which sold to Instructure (leading to his position on the Instructure board) was named in some confusing terms to either the new Blackboard CEO role or as executive chairman.

• Winter 2026: The Ellucian deal closed at the end of December, and the Encoura deal closed at the end of January. Note that Nexus also owns Encoura. And as of Friday, February 27, Blackboard emerged from bankruptcy while also announcing a new $70 million capital investment.

Nexus and Oaktree now control the company. The board structure makes this clear: Nexus and Oaktree each designate multiple directors and together anchor the executive committee, meaning the two sponsors control governance and strategic decisions.

This looks like classic PE-style structured equity with downside protection and upside optionality—not passive lender ownership. In simple terms, the sponsors built in the legal mechanisms needed to take Blackboard public, signaling that an IPO is a contemplated exit strategy, not an afterthought.

The Leadership Question

What we also now have is a clearer picture of Blackboard’s future leadership. Matt Pittinsky will be the CEO starting sometime between now and October. Pittinsky is returning as CEO, not executive chairman. That is an operational decision. The non-compete delay signals competitive sensitivity. Instructure did not treat this as a neutral move, which gives insight into how this is viewed inside the LMS market.

In the meantime, current CEO Bruce Dahlgren will stay on as a transitional CEO and member of the board until the new CEO is in place.

Blackboard operating for several months without its announced long-term CEO creates a strategic pause at an awkward moment. Major shifts are unlikely before Pittinsky formally takes control. This is a transition risk window.

Friday’s filings show that executive employment agreements, retention plans, and severance agreements were rejected in bankruptcy. The new ownership is clearing legacy compensation structures and will rebuild the leadership framework under sponsor control.

The new Blackboard will emerge strategically in the fall, even though the financial emergence has already occurred.

New Investment

The other announcement of note today is the new $70 million investment, once again signaling that Nexus and Oaktree plan to create an exit opportunity in the coming years, possibly including an IPO.

$70 million is meaningful but not transformative. It provides runway for operations, product stabilization, and selective reinvestment—particularly in sales and marketing. It is not a war chest for large-scale M&A or aggressive market expansion. Performance will still matter immediately.

Looking Forward

Blackboard Together in July will be the first visible readout of what PE sponsor control plus new capital actually means. Watch the product roadmap. Watch the sales tone. Watch whether this is stabilization or repositioning.

The financial reset is complete. The strategic reset is still to come.

Stay tuned.

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What did I read this final week of February, and what stood out? It turns out that a big issue is labor market signals—what they mean and how they are changing.

Confident in the classroom; uncertain in the market

Two recent reports caught my attention—not because they say the same thing, but because they don’t. At first glance, they appear to contradict each other. In reality, they reveal something more unsettling: the labor market signal itself is shifting under students’ feet.

The College Reality Check from Gallup and Lumina compares the views of currently enrolled students with those of the general public. It covers familiar terrain, campus climate and open dialogue, but what stood out to me was students’ confidence in their preparation for life after graduation.

Students rate the quality of their education highly.

They are also either very confident or confident that their degree or credential will help them get a job once they graduate, with at least 90% of respondents across all degree types and fields reporting confidence.

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Like last year, I attended the CSPEN policy summit in Washington, DC this month, which I have augmented with additional research. CSPEN’s February Summit is a remarkable event, bringing in key policymakers and analysts into the most information-dense meeting in all of higher ed, with just over 100 people in attendance. This year, that included congressional leaders from the House, several Department of Ed (ED) leaders, a reunion of quite a few committee members from recently negotiated rulemaking committees, a researcher from the Urban Institute, government relations insiders including from ACE and AACC, and of course CSPEN itself.

There is a fairly clear picture that emerges on not just what policies are next in play (e.g., the AIM committee on accreditation reform) but more importantly how policymakers think about these issues.

Below are four takeaways from this research and what that likely means for higher education leaders.

Context

First, I would like to share a graphic I created last April to capture my thoughts at the time. The organizing points:

• The Trump Administration has a chaotic side on the left that tends to suck a lot of oxygen out of the room and cause continual over-reaction from higher ed observers. While that chaos is there and important, there is also significant negotiations and policy work underway on the right.

• The governing themes that animate administration work (and Republican congressional efforts through OBBB) are the general anti-woke category but also shifting power to the states, transparency on pricing and outcomes, a focus on sector-neutral outcomes, and pushing to integrate higher education and workforce initiatives.

• If you focus on the chaos, at least don’t miss that there is always a Step 2; everything is a negotiation, with initial positions designed to elicit reactions.

This view of the Trump Administration higher education policy work has remained quite accurate in my opinion. But higher education at large still over-indexes on the chaos while not preparing for the policy implementation, and the importance of “sector-neutral outcomes” is not fully understood.

1. ED Wants Durable Policy

Too many observers, on both sides of the political spectrum, still view the second Trump Administration like the first, and even that is distorted by stereotypes. What animates the current administration (White House, ED, congressional leadership) is not deregulation per se or protection of favored constituencies such as the for-profit sector. Far more important is the idea that all education providers should play by the same set of rules, and that focus should be on outcomes. Hence sector-neutral outcomes.

One way that plays out is that ED wants simplified, consistent benchmarks for the earnings premium. The rationale is for the rules to stick long-term, they need to be simple—same age comparisons across all undergraduate credential types, minimal nuance in definitions. Adding nuance begs for policy editing by future administrations.

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I read a lot this week. What should I share? The through line was contrast: real money, viral panic, and students quietly building things.

The $619 million question

In the online space, marketing isn’t just a cost, it’s often a defining feature of the business model. A recent LinkedIn post from Perspective Data Science aggregates 2024 Form 990 data and shows just how large that spending has become.

The post suggests that the drop-off from the top four to the next highest spenders is not as steep as the chart would suggest.

In thinking about these data, it is worth bearing a few things in mind.

First, because these data are drawn from nonprofit 990 tax forms, they cover only private nonprofit institutions. I am not aware of a good way to access comparable marketing-spend data for public institutions. This means that institutions such as Arizona State University and Purdue Global are not included.

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A few months ago, Morgan launched her own newsletter On Student Success (subscribe here), adding to her analysis in the On EdTech newsletter and going deeper on a topic of particular interest to her. Student success is a multi-faceted topic, tying in the focus on data rather than action, the framing of durable skills, the faculty role in transfer decisions, liberal arts graduate earnings, and what happens when students are unable to enroll in the courses they need.

In examining these varied aspects of college and university life, Morgan shows that while awareness of student success challenges is widespread, the deeper problems lie in institutional systems, and in the tendency to view student success through too narrow a lens.

Her posts over the past six months ask not just whether higher education cares about student success — most institutions clearly do — but whether we are willing to deal with the challenging decisions necessary to improve how our students succeed, or not.

I have included a sample of posts below to give you a sense of the On Student Success newsletter. I am obviously biased, but I love reading her posts and learning from her insights. Give these a read and subscribe if you’re interested.

Analytics Without Action, Dashboards Without Decisions: Moving the needle on student success

In this post, Morgan takes aim at a pervasive pattern in higher education’s approach to student success: institutions identify a problem, purchase a tool (an early alert system, CRM, dashboard, etc.), implement it, and then stop. The missing link is not insight but follow-through.

She outlines several hypotheses for why this happens, but they largely converge on a common theme: institutions treat data collection and system implementation as the end goal rather than as the beginning of the work. As Morgan puts it, data must be “the start of the journey, not the finish.”

Ignoring the Obvious: An example of not seeing the elephant in the room when it comes to post graduation earnings

In this post, Morgan uses an analysis by Burning Glass economists to highlight some of the problems associated with using short-term post-graduation earnings as proxies for institutional value. The Labor Matters post focuses specifically on selective liberal arts colleges (SLACs). Graduates of these institutions tend to earn less immediately after graduation than graduates of other elite institutions, though many catch up later in their careers.

However, one of the examples the post uses, Bryn Mawr College, illustrates the difficulty of accounting for the broader forces that shape earnings, including gender discrimination and regional pay variation. The data show Bryn Mawr graduates starting at salaries well below their peers. The authors argue that they have controlled for gender, but how do you control for gender at an institution that (according to IPEDS and common knowledge) enrolls an exclusively female student body?

This is not merely a methodological oversight. It highlights the deeper problem of relying on accountability metrics that ignore structural forces and risk penalizing institutions for societal inequities beyond their control. As Morgan argues, “Punishing institutions for the latter is deeply problematic and ultimately harmful to society.”

The Other Transfer Two-Step: Faculty discretion and document demands as hidden barriers to credit transfer

Facilitating student transfer between institutions is a critical challenge for many colleges and universities. In this post, Morgan highlights new MDRC research to show that while transfer is often framed as a technical or advising problem (messy data, too few advisors, confusing requirements), many transfer barriers are in fact cultural and structural. She underscores how the MDRC study reveals a breakdown in the transfer “two-step”: credits may be accepted by the receiving institution but never actually applied toward a major. This disconnect significantly delays student progress and increases time and cost to degree.

These breakdowns often stem from the faculty role in evaluating transfer credits. Factors such as skepticism about the quality of instruction at community colleges, minor catalog description mismatches, and unrealistic or burdensome documentation requests can lead to lengthy review processes in which credits ultimately do not count toward a course of study.

As Morgan argues, the issues highlighted in the MDRC study are critical because most “best practices” overlook faculty discretion and the documentation burden. Until institutions address how faculty roles, standards, and evidence requirements operate within the transfer process, meaningful improvement is unlikely.

Two Problems I Have With Durable Skills: Missing the most important one, and mis-framing the rest

Current conversations about student success and higher education accountability inevitably include some discussion of soft or durable skills. In this post, Morgan takes aim at the concept, arguing that much of this coverage is frustrating because it omits the most important meta-skill: learning how to learn. She also critiques the tendency to frame durable skills as relevant only to the workforce, rather than as essential for success during college itself.

Morgan argues that we need to conceptualize durable skills around the capacity to learn — and to recognize them as critical to student success while students are still enrolled, not merely after they graduate.

Yes, Students Getting Shut Out of Courses is a Big Deal for Student Success: New (ish) research shows us how

In this post, Morgan synthesizes two innovative research streams (one on community college waitlists in California and another on a unique exercise in allocating course places at Purdue based on an algorithm) to overturn the old assumption that course shutouts don’t matter. While overall four-year graduation rates may not shift dramatically, shutouts increase stop-out risk, reduce likelihood of ever completing the course or subject, affect major choice and produce gender-differentiated labor market impacts. Morgan uses these important studies to show that in order fully to understand student success, we need to look at issues such as being shut out of courses.

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It is Valentine’s Day, and here on the Wasatch Front nature seems to think it is already spring. But what did I read this week, and how did those readings shape my thinking?

There are moments in higher education when the temperature drops. Not catastrophically. Not dramatically. Just enough for the shine to fade and the conversation to shift from expansion to evaluation.

This week’s reading feel like one of those moments. Microcredentials are moving from promise to requiring proof. Online enrollment strategies are revealing operational cracks. Skepticism about online learning is resurfacing at governing boards, even as the data show more nuance than the rhetoric suggests.

Taken together, these pieces point to something deeper than isolated challenges. Higher education may be entering a phase where enthusiasm is no longer enough. The question is no longer whether innovations sound compelling, but whether they can withstand scrutiny.

The bloom is off the rose

The bloom may not be entirely off the rose for microcredentials, but institutional enthusiasm is clearly cooling. Two recent reports suggest that the initial wave of optimism is giving way to scrutiny — financial, operational, and labor-market based.

Redefining return, and still falling short

The Burning Glass Institute assembled a dataset linking the career histories of 65 million Americans to more than 20,000 credentials across 2,056 providers. Using this Credential Value Index, they push back on approaches that measure return on investment for microcredentials solely in terms of immediate earnings, as is the case with Workforce Pell and some state accountability frameworks.

Rather than asking only whether credentials raise pay in the near term, Burning Glass examines whether microcredentials enable promotions or transitions into higher-opportunity occupations over time.

Based on analyses of data in their merged dataset, they classify microcredentials into four categories: Launchpads, Promotion Catalysts, Lateral Moves, and Dead Ends. Even under this broader definition of value, roughly two-thirds still fail to deliver measurable wage or mobility returns.

Launchpads: credentials that help earners transition into new careers with substantial wage gains (6% of credentials)

Promotion Catalysts: credentials that facilitate upward movement within the same field (8% of credentials)

Lateral Moves: credentials that help workers shift into different occupations with higher long-term opportunity, even if immediate wage gains are modest (17% of credentials)

Dead-End Credentials: credentials that show little measurable wage or mobility impact (69% of credentials)

The second part of Burning Glass’s analysis asks a different question: how do wages evolve over time for earners relative to comparable peers? Instead of focusing only on immediate post-credential earnings, the authors track wage trajectories relative to a matched comparison group over a five-year period.

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This morning I published a post with revised and more extensive coverage of the combined NC-SARA and IPEDS data showing the connection between institution state and student state for fully online enrollments. The chart type is brand new, at least for this analysis, and I’ve got some very good reader feedback, so I thought a quick follow up might be useful.

The ASU View

Since the original story was triggered by ASU’s expansion with California students, it would help to not just see the California Student State view but also the ASU Institution view.

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Late last week in a premium post, I took a deeper dive into a story about Arizona State University’s (ASU’s) attempts to further expand in California by being eligible for Cal Grants (which California is fighting). The EdSource article focused on one institution and one policy decision. But the larger story is about geography.

Online higher education is often described as borderless. In practice, it is anything but.

This analysis focuses on interstate online enrollment patterns using NC-SARA Fall 2024 exclusive distance education data. NC-SARA is the organization that administers the State Authorization Reciprocity Agreement (SARA), and it collects data on students enrolled fully online (i.e., exclusive distance education) across state lines. Using Fall 2024 data (combining undergraduate and graduate students), we can see something that IPEDS alone does not show: where fully online students actually live, and where they enroll. That distinction matters. IPEDS reports enrollments by institutional location; NC-SARA allows us to trace interstate demand.

What emerges is not a flat national market. Instead, we see a set of state-level markets with distinct patterns. State policies matter. Some states export enough students to shape other markets. Some retain a high percentage of their own residents. Others leak substantial demand while still hosting online programs of note.

Below, I walk through the national picture and then examine several states in more detail. See the end of the post for additional data notes.

United States

Before looking at California, here’s the US map that makes the state examples make sense.

• 63.6% of students in fully online programs are enrolled in same-state institutions, which is quite close to the IPEDS data for Fall 2024 showing 62.4%.

• The biggest state fully online enrollments are California, Texas, Florida, Georgia, and North Carolina. This is also the top list for same-state fully online enrollments.

• The biggest state fully online out-of-state enrollments (whose institutions enroll out-of-state students nationwide) are Arizona, Utah, New Hampshire, and Virginia.

• The biggest institution enrollments of out-of-state students nationwide are WGU, SNHU, UoP, Penn Foster College, Grand Canyon University, Liberty University, and ASU. It’s interesting how much of ASU’s out-of-state enrollments are from California - it does not have the broad-based nationwide footprint as the others.

From an initial view, states appear to fall into three rough categories: strategic out-of-state targets (large numbers drive other state strategies), retention states (most online students stay in-state), and leakage states (large shares enroll out-of-state). The examples below illustrate the different patterns.

Strategic Out-of-state Target Example: California

Even though we don’t have NC-SARA data on California institutions, I was able to substitute IPEDS data to fill in the gaps. Although not shown below, California institutions enroll remarkably few out-of-state students, just ~53,000. Yet a lot of California students are in fully online programs. Only Texas sends more online students to out-of-state institutions. It is interesting to note that California is not merely exporting students — it is exporting them primarily to a handful of scaled institutions — which I suspect is due to those large institutions being able to navigate the state authorizations without SARA.

Some observations (starting from the left and moving right):

• California has 791,234 students in fully online programs, with a surprisingly high percentage (78%) in in-state programs. These are dominated by community colleges as well as National University.

• California has 177,763 students as of Fall 2024 in fully online programs based in other states.

• Arizona institutions enroll 29% of those students, split between multiple institutions—ASU, University of Phoenix (UoP), Grand Canyon University (GCU), Penn Foster College, among others.

• Utah (primarily through Western Governors University) enrolls 14% of those 177,763 students, followed by New Hampshire, and Florida.

• The top Other State institutions enrolling California residents are (in order): SNHU, WGU, ASU, UoP, GCU.

Paxton Ritter’s commentary on the premium post data is worth reading.

ASU’s presence in California is not accidental or marginal. It reflects a deliberate strategy grounded in the belief that educational mission should not stop at state borders — and that California students are actively seeking scaled, high-quality online options beyond their in-state system.

Retention Example: Arizona

Besides Arizona institutions enrolling a lot of out-of-state students, we can also see that this state retains a great deal of its own residents that are in fully online programs. Nearly three-quarters of them.

• This retention of fully-online students is largely through ASU, GCU, UoP, and Rio Salado College. This is quite different than California’s community college dominant provision of same-state online enrollments.

• Of the 25% of Arizona-based fully-online students who enroll in out-of-state institutions, the top ones are WGU, SNHU, Liberty, and American Public University System.

The payoff for scaled online programs is not limited to out-of-state expansion; it also includes serving large numbers of in-state students.

Leakage Example: Washington

At the opposite end is Washington, where resident students split roughly evenly between same-state and out-of-state institutions, below the 63 / 37 national average.

• Washington institutions only retain 51% of its fully-online students.

• WGU has a very large presence in this state, largely based on the 2011 state legislated decision.

Putting It Together

These patterns are not just descriptive curiosities.

If states increasingly condition aid, regulatory approval, or performance funding on in-state presence, earnings outcomes, or labor market alignment, then interstate online flows become more than enrollment trivia. They become policy targets.

California’s Cal Grant decision involving ASU is one early example of this dynamic. But the NC-SARA data suggest a broader reality: a small group of institutions operate as national exporters, while many states function primarily as retention markets. Others, like Washington in our example, appear comparatively porous.

Online higher education may be delivered through broadband, but its economics and politics remain grounded in state lines. The geography is not disappearing. It is becoming more visible.

We will do more work to further develop our analysis, but I hope this early view is illustrative and sets the stage.

Premium subscribers will see additional state analyses.

Data Notes

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Toward the end of last year, I gave a presentation on the future of online learning at the Coalition for Networked Information. CNI has posted a video of the presentation, which may be of interest.

But enough of this new-fangled video technology. What did I read this week, and was anything interesting?

Much of what I read kept coming back to the same theme: institutions continue to design systems around their own assumptions, even as students, their behaviors, and labor markets are changing underneath them.

Personalization isn’t what it used to be

A new report from UPCEA and Collegis offers a useful illustration of a broader problem in online student support. Much of what it describes will be familiar: the reasons students find online learning challenging, and why so many stop out.

But the report also contains two striking findings.

The first is the truly depressing fact that 48% of the institutional leaders surveyed did not know their own institution’s retention rate. This is a small sample, but it is still unacceptable. Metrics are imperfect, but not having even this basic level of insight speaks volumes about how seriously institutions are taking online learning and student success, and nothing in those volumes is good.

The second finding points to an increasingly familiar theme in student success: the disconnect between what institutions think is effective and what students say they actually need.

I like the oversight-versus-autonomy framing, but I think it is worth digging into a bit more. If you look closely at the categories, the pattern is telling. Students consistently favor technological tools that provide clear, timely information. Institutions, by contrast, almost always favor people reaching out and having conversations.

What this suggests to me is a misunderstanding about the nature of personalization.

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From EdSource:

This story fits in perfectly with our developing coverage of the NC-SARA data on exclusive distance education (DE) enrollments, looking at both the student state (where they reside) and the institution state (where the main campus or operation is located). This augments our IPEDS coverage which is based on institution state only.

Just how big is ASU’s online cross-state footprint in California and does this point to a broader policy debate? It would help to have better context. The chart below is designed to show not just how many California students enroll online out of state, but where that demand concentrates—by institution and by institution state.

Import, Export, and Internal Markets: What We Mean

When we look at cross-state online enrollment, it helps to borrow basic trade terminology.

• Import market: Students who live in a state but enroll in out-of-state online programs. From the student’s perspective, education is being “imported” from elsewhere.

• Export market: Students who live outside a state but enroll in online programs offered by institutions based in that state.

• Internal market: Students who live in a state and enroll in online programs offered by in-state institutions.

California is a special case because it does not participate in SARA, so we only see its import market (California residents enrolled in out-of-state online programs), not its internal or export markets, in NC-SARA data. Therefore the first chart cannot show whether California institutions are retaining or exporting online students—only how much California relies on imports. Indiana in the second chart, by contrast, allows us to see all three markets at once, which makes it a useful comparison.

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Accountability has finally arrived as a front-burner issue in higher education policy. The One Big Beautiful Bill (OBBB) accountability framework has drawn understandable attention as federal rules move toward finalization. But what’s striking, and easy to miss, is that state policy is already moving, even before the federal ink is dry.

In recent weeks, multiple states have advanced legislation tying state funding, program approval, or institutional liability directly to federal accountability concepts.

• Late last week, Indiana’s state senate just passed a bill to cut off state funding for “low-earning programs” based on the OBBB definitions.

• One week earlier, a bill was introduced in Nebraska to the same effect.

• On the same day (January 21st), a bill was introduced in New Hampshire, also seeking to cut off state aid to “low-earning programs.”

All of this happening even though the US Department of Education (ED) won’t have the new rules completed until July.

Stepping back from individual bills reveals a deeper and more consequential pattern. States aren’t just debating whether to hold higher education accountable. They are adopting very different answers to a more fundamental question:

What determines the value of higher education?

Right now, three distinct, and increasingly competing, approaches are emerging. Which one gains momentum will shape higher education far more than the details of any single rule.

1. Earnings as a gatekeeper: value equals ROI

The first approach treats return on investment as the decisive test of value. This is the logic embedded in the federal Gainful Employment / OBBB framework and now being debated in states such as Indiana, Nebraska, and New Hampshire.

Under this model, earnings are not merely informative. They are determinative. If a program fails an earnings test—typically defined as falling below a national high-school benchmark—it is presumed to lack sufficient value unless the institution can justify an exception.

Proposed state statutes increasingly echo this posture with language referencing:

• “Low-earning outcome programs” as defined in federal law

• Mandatory approval requests to continue affected programs

• Restrictions on state funding tied directly to earnings outcomes

The appeal is obvious. This approach is simple, portable, and bipartisan. States don’t need to invent metrics or build new data systems; rather, they can simply import federal definitions and thresholds.

But that simplicity rests on a strong assumption: that earnings premium is the primary determinant of educational value. Other considerations such as regional labor markets, institutional mission, or public-service roles may be acknowledged rhetorically, but they do not override the metric.

I’ve written before about the flaws of this blunt-instrument approach, especially its tendency to penalize regionally focused institutions and workforce programs serving lower-wage labor markets. Since the benchmarks tend to be state-level medians, programs located in lower-income areas have to increase earnings much more than for programs in higher-income areas to pass the test.

What’s new is not the metric, but how quickly states are beginning to jump on the bandwagon.

2. Earnings as one signal among many: value as performance

A second approach, exemplified by Florida and Texas, the latter for the community college system, reflects a very different philosophy, even though graduate earnings still matter. Other examples that include some level of graduate earnings include Tennessee, Ohio, and Washington.

In these systems, earnings are embedded within multi-metric performance frameworks. They help shape funding allocations or institutional comparisons, alongside measures such as completion, access, workforce alignment, and improvement over time.

Statutory and regulatory language emphasizes:

• Performance metrics and weighted outcomes

• Relative institutional performance

• Incentives rather than disqualification

Here, return on investment (ROI) is a signal, not a veto. Programs and institutions are not deemed valueless because of one outcome. Instead, earnings contribute to a broader picture of performance.

This approach treats value as multi-dimensional. Economic return matters, but it does not settle the question on its own.

It’s also harder to build. Performance-based funding systems require negotiation, institutional buy-in, and sustained political commitment. Which helps explain why, despite their sophistication, they are not the path of least resistance.

3. Risk sharing: value inferred from repayment failure

A third approach is being considered in Iowa and somewhat mirrors earlier House Republican proposals under the College Cost Reduction Act (CCRA).

Rather than focusing on earnings benchmarks, this model defines value through student loan repayment outcomes. Institutions would be financially liable for a share of student loan defaults, effectively sharing downside risk when students cannot repay.

The core logic is different but related:

• If students can’t repay, the program failed to deliver sufficient economic value

• Institutions should internalize some of that failure

This approach avoids explicit earnings comparisons, but it still embeds a strong economic assumption: repayment success is the ultimate test of value, regardless of other benefits.

It’s not just statutes: non-legal signals point in the same direction

What makes this moment especially important is that the shift isn’t confined to legislation.

State systems and commissions are also shaping how value is discussed and normalized. For example, the University of North Carolina System recently released an ROI study estimating a $500,000 median lifetime return for its graduates. That’s not regulation, but it sends a clear signal to policymakers and the public that earnings-based analysis is a legitimate way to talk about higher education’s worth.

Similarly, efforts like the Postsecondary Value Commission are advancing frameworks that place earnings, repayment, and labor-market alignment at the center of value discussions. These initiatives matter because they help define what metrics feel credible and reasonable long before they appear in law.

Together, these non-legal moves reinforce the same trend: economic return is becoming the dominant language of value, even when it’s not yet the dominant enforcement mechanism.

Emerging Model Comparison

Stepping back, the differences become clearer when you line them up¹ .

Why the OBBB approach may be gaining momentum

These three approaches are not easily compatible. You can’t simultaneously treat earnings as a hard eligibility gate, a contextual performance signal, and a back-end risk-sharing trigger without creating conflicting incentives.

Yet the earnings-gatekeeper model appears to be gaining momentum for a simple reason: it’s the path of least resistance.

Federal definitions already exist. The politics are straightforward. The enforcement is clean. States can act quickly without building new frameworks or reopening value debates from scratch.

Ease of adoption, however, is not the same as quality of design. And we’ll have to see if any of the new bills succeed and become statute.

Implications

Looking beyond the details, it appears that we are entering a period of competition over how value itself is defined.

If the earnings-premium model becomes the default—not because it’s best, but because it’s easiest—institutions will increasingly be judged through a single economic lens, even as leaders continue to talk about access, mission, and regional impact.

This is a moment to pay attention to trajectory, not just detail. The rules are still evolving, but the direction of travel is becoming clearer.

Stay tuned.

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What all happened in EdTech, and what did I read this week?

Everything pointed to the same uncomfortable truth: there are no easy solutions in the complex system that is higher education. Tools, practices, and jobs exist within larger systems, and changing them without understanding that complexity is likely to unleash a lot of unintended consequences.

Tools depend on teaching

New research from folks at the University of Toronto, Stanford, and Khan Academy sheds some interesting light on the impact of tutoring platforms, such as Khan Academy itself.

It is a dense piece of research to parse, but it offers several findings that confirm what we already know about online tutoring (or computer-assisted learning, CAL), alongside others that raise new questions.

It is also a strong piece of empirical work, drawing on a large dataset and a quasi-experimental design, a welcome change from the endless randomized controlled trials in this space and their often questionable findings. Much of the existing evidence on tools like Khan Academy comes from idealized experiments, leaving open the question of whether they work under messy, everyday conditions.

As I mentioned, it is a complex argument, so I will let the authors describe their method.

The good news is that they find the tool improves math scores. Even at fairly low levels of use—about 11 minutes per week, compared with the recommended 30—students’ scores improve. They also find a roughly linear relationship between usage and learning: more use leads to more improvement. And, as we have come to expect from many studies of EdTech, stronger students tend to benefit more than weaker ones.

One intriguing, but ultimately intensely frustrating, aspect of the research is the authors’ use of the concept of teacher efficiency. If you dig into the report, though, it gets to the heart of the matter, so bear with me.

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Anthology on Track to Become Blackboard Soon

At this point, Anthology’s Chapter 11 bankruptcy case is in the execution phase. The Ellucian transaction has closed as planned, and all signals from the docket suggest the Encoura acquisition of the CRM and student success businesses is on track to close shortly. Importantly, there is nothing in the recent filings to indicate a deviation from the original Day 1 framework. The reorganization around Blackboard teaching and learning remains intact, financing terms are settled, and there is no sign of any alternate deals or changes to the plan.

The next visible milestone should be leadership clarity for the reorganized Blackboard business. Matt Pittinsky has been announced as incoming Executive Chairman, but the Plan Supplement filings still leave open questions about day-to-day executive leadership. I expect we will see confirmation soon, either of a newly named CEO or a defined interim structure, along with clearer articulation of Pittinsky’s operational role and timing. For customers and partners, this governance clarity matters more than the legal mechanics of emergence.

What stands out most, however, is how smooth this bankruptcy has been. Asset sales are closing on schedule, the core business continues operating, and there has been no sign of a mass client panic or disorderly market reaction. Once distressed-debt investors took control, the process appeared to shift from uncertainty to predictability, and Anthology has largely delivered on the plan it put before the court. Given how chaotic this process could have gone, that is no small accomplishment.

It appears that the new Blackboard will come out this bankruptcy better than I expected, according to plan and without mass defections.

Stay tuned.

ED Releases Formal Draft Rules on Student Loan Limits: What Matters Now

As expected, the Department of Education (ED) today released the formal Notice of Proposed Rule Making (NPRM) implementing new federal student loan limits, and the core policy choices largely track the consensus reached during fall negotiated rulemaking. That part is not the news.

The news is in two places:

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Friday’s post showed exclusive distance education (DE) enrollment by student location based on NC-SARA data, revealing strong regional patterns even after excluding California institutions (as that state does not participate in the State Authorization Reciprocity Agreement). The top chart shows Exclusive DE enrollments by the Institution’s state, with variation from the average (red = below average, green = above). The bottom chart shows the same, using NC-SARA data, based on the student location.

What the original chart already told us (and still does)

A few points are worth restating briefly:

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Ah, the joys of technology. It took me a while to get here today, but what did I read this week?

In very different ways, much of what I read pointed to the same underlying question: where learning is happening, who controls it, and how much of it is slipping outside institutional boundaries.

Where learning happens

Wheelhouse, the Center for Community College Leadership and Research at UC Davis, has an interesting report on how the expansion of online course offerings has reshaped enrollment geography in California’s community college system over the past decade.

The headline finding could be seen as somewhat counterintuitive: online enrollment has surged, but course-taking remains strikingly local. Using system-wide administrative data from 2014–15 to 2023–24, the authors analyze first-time students across most California community colleges (excluding the fully online Calbright College), focusing on modality, distance from home campus, and cross-enrollment across institutions. I am especially interested in whether students are using online courses to study at a distance, so that is where I concentrate.

Since the pandemic, participation in online learning has increased dramatically, but most of that growth has come from students taking a single online course, what the report describes as multimodal enrollment.

Despite the growth in online enrollments, course-taking behavior remains largely local. The report defines a non-local campus as one more than 30 miles away (about 48 kilometers for those of you in the rest of the world who enjoy the indignity of a rational measurement system). Using students’ ZIP codes and their “initial home colleges,” the institutions where they took the most credits in their first term, the authors track how far students actually range.

For students in the any-modality group (the red line), the pattern is strikingly stable: most continue to take courses locally, and that rate barely budges over time. Online only students taking of courses more than 30 miles away declined up until the pandemic but have been increasing sharply since then.

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In this week’s Future U podcast by Jeff Selingo and Michael Horn, they discussed the IPEDS distance education (DE) data analysis I have provided in this free post and this premium post. In that latter post, I included a map-based view showing the breakdown per state of modality - Exclusive DE (fully online students, Some DE (mixed-modality students), and No DE (fully campus-based students). My point was that distance education participation remains highly uneven geographically, reflecting both institutional concentration and legacy campus systems.

Jeff noted in the podcast our discussion about institution vs. student location views [emphasis added].

It turns out that there is still geographic variation of exclusive DE adoption by student location, just not as much as by institution location and in different patterns. Let’s look at this issue in more depth.

Exclusive DE Institution Locations

This is a view of the Top 100 institutions by Fall 2024 Exclusive DE enrollments based on the IPEDS institution unit (i.e., this view is slightly different than the institution rankings where I have combined campuses that operate collectively). Here we see specific locations and not just state groupings.

With this location view, you can get a better sense of national online brands setting much of the geographic distribution. SNHU dominates New Hampshire, WGU dominates Utah, several institutions dominate the mid-Atlantic region. And then there is Arizona.

This area is home to the University of Phoenix, Grand Canyon University, ASU, and others. In fact, this view understates the concentration since IPEDS is ridiculously out-of-date in updating institution changes and still shows University of Arizona Global Campus as its old name and location: Ashford University in San Diego.

NC-SARA and Student Location

I have been remiss in publicly analyzing the NC-SARA data, so treat this as an initial addition of this coverage.

NC-SARA is the group administering the State Authorization Reciprocity Agreement (SARA), of which 49 states participate. California is the one holdout. And as part of this work, NC-SARA publishes data on the student location for each institution’s exclusive DE enrollments, by state.

To get similar measures of the percentage of students per state taking exclusive DE programs, there are different data sources required.

• By Institution Location - The data comes from the IPEDS data release noted above.

• By Student Location - Here I take the NC-SARA data on raw student numbers (number of students in each state in exclusive DE programs, regardless of institution location) as the numerator. I then use Census Bureau ACS data to estimate the total number of postsecondary students residing in each state, using that as the denominator.

Here are some initial observations, and note again that California is excluded as that state does not participate in SARA.

• Greater Variation by Institution - This gets to Jeff’s point that there is less regional variation by student location (ranging from 11% in Rhode Island to 37% in Alaska, not shown) than by institution location (ranging from 12% in Michigan to 81% in New Hampshire).

• But Still Meaningful Geographic Variation by Students - However, there is still a very meaningful variation to consider. Jeff posited that “even if you have a campus down the street, if online education for the modern learner works for you better, you're going to do it.” We still have a number of states (AK, KY, GA, MS, WY, SD, NM) with 30% or more of postsecondary students in exclusive DE programs and also a number of states (RI, DC, MA, NY, VT) with 15% or less.

• Very Different Pattern - It is also interesting to note that the states with the highest percentages of exclusive DE enrollments by institution (NH, UT, AZ, MN, WV) all have below average percentages when measured by student location.

We plan to do some deeper analysis at On EdTech+ in future posts.

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Before getting into updates on On EdTech+, I want to flag an upcoming live event that I think many of you will find valuable.

The Big Conversation at UNS / ACE Next Month

I’ll be moderating a cross-administration unscripted conversation with current Under Secretary of Education Nicholas Kent and former Under Secretary of Education James Kvaal, focused on the future of higher education policy. This conversation, sponsored by Noodle and Huron, will occur February 26th at the University Network Summit @ ACEx2026 in Washington, DC.

Details and registration information for the full UNS@ACE event February 25 - 27 are available at this link.

Conversations like this, bringing together current and former policymakers with very different perspectives, are a big part of why On EdTech exists. And I will be covering the conversation in a post-event article.

With that context, I want to share an update on how we’re evolving On EdTech+ and our broader offerings.

Who Is Not Affected

To avoid confusion up front:

• Free On EdTech subscribers will continue to receive full access to free posts. We will continue to publish one or two free posts per week.

• Subscribers who receive premium On EdTech+ access through:

  • WCET membership; or

  • On EdTech Enterprise / PH&A Advisory memberships.

If you’re in one of these groups, you will see no changes other than improved content.

A Clearer Separation of Offerings

Over the past few years, it’s become clear that different readers want different kinds of engagement.

PH&A Advisory Memberships: Access and Engagement

Phil Hill & Associates (PH&A) Advisory Memberships are now explicitly centered on:

• direct access to me or Glenda Morgan or Kevin Kelly;

• scheduled briefings and discussions;

• and tailored analysis for leadership teams.

This is the right fit for organizations that want ongoing dialogue, interpretation, and decision support, not just written analysis.

On EdTech+: Analysis You Can Use

Access to On EdTech+ doesn’t change (upgrade here and see instructions to manage your subscription here), but the content is being sharpened around what individual subscribers consistently say they value most:

• more topical, timely posts reacting to policy and market shifts;

• usable analysis, not background explanation;

• and special reports that go deeper than a standard newsletter post.

On EdTech+ is not becoming an advisory service. It is becoming more focused, more analytical, and more immediately useful.

As other higher-ed outlets experiment with new paywall models, On EdTech’s free tier remains fully accessible. The changes here are about making the premium tier more valuable, not narrowing access to the public conversation.

On EdTech+ Price Change (Effective March 1st)

Starting March 1st, the price of On EdTech+ will change from:

• $10/month to $20/month, or

• $100/year to $200/year for annual subscriptions.

This reflects both the depth and frequency of premium analysis and the clearer separation between individual subscriptions and advisory access.

This change may alter the plans for some readers, and that’s okay. On EdTech has always been designed to be useful at multiple levels.

Lock In the Current Price Before March 1st

If you’re currently:

• a monthly On EdTech+ subscriber, or

• a free subscriber considering upgrading,

you can lock in the current $100/year price for twelve months by switching to an annual plan before March 1st. Go to Top Right Icon > Manage Subscription > Billing > Change Plan in the Your current plan box.

Coming Soon: A Resharing Plan

One pattern we see consistently is that On EdTech+ analysis is shared within organizations, private email lists, and internal discussions—and sometimes referenced publicly.

Rather than fight that behavior, we’re designing a Resharing Plan to explicitly support appropriate shared use while keeping the work sustainable. I’ll share more details in the coming weeks.

Why We’re Making These Changes

These updates are about:

• aligning pricing with how the work is actually used;

• aligning offerings with reader and client needs; and

• sustaining independent, data-driven analysis in a policy and market environment that continues to accelerate.

As always, thank you for reading, sharing, and engaging with On EdTech, whether as a free subscriber, a premium reader, or an advisory client.

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Morgan wrote an excellent post yesterday at On Student Success (subscribe here if you haven’t already), with the initial section on High School Dual Enrollment (HSDE).

Her post then describes analysis from both AACRAO and CCRC on how we need to think about HSDE differently, both in design and business models, with Morgan adding her notes to frame dual enrollment as an upstream investment in student success.

Read her whole post (and the links) for the student success angle.

Relationship to Enrollment Gains

But this view also aligns with questions I have received about the latest IPEDS enrollment data, along the lines of “how much of the enrollment gains over the past few years are explained by HSDE instead of organic growth?”

As we have noted several times, this question is important as HSDE places a structural risk on colleges and universities. The business model / financials are different, and as Morgan notes, the support and framing around student success are different. Simply bundling HSDE growth into overall enrollment gains can hide some core challenges to address, even if the numbers are growing (for now).