MARYLAND HIGHER EDUCATION COMMISSION - MEETING BOOKLET Time: 1:00PM Wednesday, March 24, 2021
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MARYLAND HIGHER
EDUCATION COMMISSION
MEETING BOOKLET
Time: 1:00 PM
Wednesday, March 24, 2021
Place: Video Teleconference
(GoToMeeting)Maryland Higher Education Commission
Andrew R. Smarick, Chair
Donna M. Mitchell, Vice Chair
Senchal D. Barrolle, Esq.
Vivian S. Boyd, Ph.D.
Lewis R. Brown, Ed.D.
James E. Coleman
Vera R. Jackson, Ph.D.
Charles McDaniels, Jr.
Sydney Miller, Student Commissioner
James B. Sellinger, Sr.
Mary Pat Seurkamp, Ph.D.
John W. Yaeger, Ed.D.
James D. Fielder, Jr., Ph.D.
Secretary
Lawrence J. Hogan, Jr. Boyd K. Rutherford
Governor Lt. GovernorLarry Hogan
Governor
Boyd K. Rutherford
Lt. Governor
Andrew R. Smarick
Chair
James D. Fielder, Jr., Ph. D.
Secretary
Maryland Higher Education Commission
Meeting Agenda
TIME: 1:00 p.m. PLACE: Video Teleconference
Wednesday (GoToMeeting)
March 24, 2021
Action
Page Item
Call to Order
Chair’s and Secretary’s Remarks
Public Comments
Commission Minutes Approval………………………………………………………….1 *
• February 24, 2021
Commissioner Committee Updates
Department of Finance and Administration – Mr. Geoffrey Newman
Office of Student Financial Assistance – Ms. Donna Thomas
Final Adoption of Amendments to COMAR Financial Aid Regulations –
Richard W. Collins III Leadership with Honor Scholarship Program….………………….5 *
Education Policy Committee – Dr. John Yaeger, Committee Chair
Strayer University’s Request for Waiver of Full-Time Faculty Definition………………..7 *
Adjournment
*The next Commission meeting is on Wednesday, April 28, 2021 @ 1:00 PM.
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.govMaryland Higher Education Commission
Meeting Minutes
February 24, 2021
1:00 p.m.
The Maryland Higher Education Commission (MHEC) met on Wednesday, February 24, 2021
via video teleconference (GoToMeeting).
Commission members present:
Andrew R. Smarick, Chair Vera R. Jackson, Ph.D.
Donna M. Mitchell, Vice Chair Charles McDaniels, Jr.
Senchal D. Barrolle, Esq. Sydney Miller, Student Commissioner
Vivian S. Boyd, Ph.D. Mary Pat Seurkamp, Ph.D.
Lewis R. Brown, Ed.D. John W. Yaeger, Ed.D.
Commission members absent:
James E. Coleman James B. Sellinger, Sr.
Staff members present:
James D. Fielder, Ph.D. Emily A. A. Dow, Ph.D.
Geoffrey Newman Jennifer Katz
Soma Kedia Trish Gordon McCown
Lee Towers Tavon Vinson
Karen King-Sheridan Jacqueline Cade
Bryson Barksdale Jermal Butler
Alexia Van Orden Donna Thomas
Glenda Abney
Call to Order
The meeting was called to order by Chair Smarick at approximately 1:01 p.m. A meeting
quorum was established with ten (10) members present.
Chair’s Remarks
Chair Smarick remarked that he was glad to be with everyone again, and he thanked the staff
for the meeting documents.
Secretary’s Remarks
Secretary Fielder reported that the legislative session was ongoing, and that Senate Bill 1
Historically Black Colleges and Universities – Funding was expected to pass. It would take
1effect in FY 2023. He also announced that Notre Dame of Maryland University has rescinded its
request for the Commission to review the denial of their proposed undergraduate program in
Actuarial Science. (Morgan State University had objected to the proposed program, as it has an
undergraduate degree in Actuarial Science, a unique program at an HBCU.)
Commission Minutes Approval
Commissioner Jackson motioned to approve the December 16, 2020 closed session meeting
minutes and the January 27, 2021 meeting minutes, and Commissioner McDaniels seconded the
motion. The motion was approved unanimously.
Commissioner Committee Updates
There were no Commissioner Committee updates.
Department of Finance and Administration – Office of Student Financial Assistance –
Approval of Proposed Amendments to COMAR Scholarship Regulations – Delegate
Howard P. Rawlings Educational Excellence Awards Program – Action Item
Chair Smarick recognized Mr. Geoffrey Newman, Assistant Secretary for Finance and
Administration, who asked Ms. Donna Thomas, Director of the Office of Student Financial
Assistance, to present this item. Ms. Thomas stated that she is requesting approval to publish
proposed amendments to the Howard P. Rawlings Educational Excellence Awards Program
COMAR regulations 13B.08.10. The amendments include:
• Removal of term “alternate application”;
• Defining ”Maryland State Financial Aid Application” and inserting the acronym of
MSFAA appropriately throughout the regulations;
• Adding institutional requirements for institutions that elect to verify eligibility for
Guaranteed Access Grant recipients;
• Clarify the selection of recipients process;
• Clarify the verification of eligibility requirements that are to be performed by MHEC
and post-secondary institutions to align with statutory requirements;
• Adding new appeal criteria for Guaranteed Access Grant applicants that miss the March
1 FAFSA/MSFAA deadline; and
• Clarify the institutional audit requirements for any post-secondary institution that elects
to complete the verification process for Guaranteed Access Grant recipients.
Ms. Thomas recommended that the Commission approve for publication in the Maryland
Register the proposed amendments for the Howard P. Rawlings Educational Excellence Awards
Program, and authorize MHEC’s attorneys to approve non-substantive revisions as necessary to
conform the proposed regulations to the stylistic and formatting requirements of AELR and of
the Division of State Documents. Commissioner Boyd made a motion for approval, and
Commissioner Mitchell seconded the motion. The motion was approved unanimously.
2Department of External Relations – Legislative Update – Information Item
Chair Smarick recognized Mr. Lee Towers, Executive Director of External Relations, who
reported on the progress of the 2021 legislative session. Senate Bill 1/House Bill 1 Historically
Black Colleges and Universities – Funding is a bill that would have a large impact on MHEC.
At this point, neither bill is scheduled for a hearing, and both are a little different. SB 1 uses the
Cigarette Restitution Fund as an additional funding mechanism. Senate Bill 965/House Bill
1372 Blueprint for Maryland’s Future – Revisions is another bill that would affect the agency.
However, it has not been scheduled for a hearing yet. Additionally, the budget hearings have
been progressing well.
Department of Academic Affairs – Report on Institutions of Higher Education Program
Review: Secretary Actions for Quarter 4 (October 1, 2020 to December 31, 2020) –
Information Item
Chair Smarick recognized Dr. Emily Dow (MHEC’s Assistant Secretary for Academic Affairs)
who asked Ms. Trish Gordon McCown (MHEC’s Director of Academic Affairs) to present this
item. Ms. McCown provided an overview of the Secretary’s actions during the 4th quarter
concerning a program objection, new degree programs, certificate programs, areas of
concentration, substantial modifications to existing programs, non-substantial modifications to
existing programs, proposals withdrawn, institutional program partnerships, and out-of-state
institutions.
Chair Smarick asked if there was anything of note in the report. Ms. McCown pointed to
Towson University and Loyola University Maryland’s actions under Institutional Program
Partnerships. Both schools withdrew a number of programs from their off-site locations.
Commissioner Boyd asked the reason for these closures, and Ms. McCown responded that she
would have to look it up, as she did not have specific details.
Department of Academic Affairs – Report on Private Career Schools: Secretary Actions
for Quarter 4 (October 1, 2020 to December 30, 2020) – Information Item
Chair Smarick recognized Ms. McCown who provided an overview of the Secretary’s actions
during the 4th quarter concerning the approval of a new school, certificate renewals, school
approvals withdrawn, workforce development sequence scholarship approvals, workforce
development sequence scholarship modifications approved, transcripts requested, and training
provider questionnaires.
Chair Smarick inquired about the frequency of private career schools closing. Dr. Dow
answered that, typically, within any 12-month period, there is at least one private career school
that closes. There is a variety of reasons for which a school decides to close.
Department of Academic Affairs – Approval of Proposed COMAR Amendments –
Maryland Instructor Certification Review Board Regulations – Action Item
3Chair Smarick recognized Dr. Dow who introduced Ms. Alexia Van Orden, MHEC Staff
Liaison to the Maryland Fire-Rescue Education Training Commission (MFRETC). Ms. Van
Orden gave an overview of the Commission, which consists of volunteer & career firefighters, as
well as emergency medical services personnel. The Maryland Instructor Certification Review
Board (MICRB), whose regulations are being considered, was established by MFRETC for the
purpose of developing and maintaining standards for instructor excellence. She then introduced
the Chair of MFRETC, Mr. John Jerome, Deputy Chief of Howard County Fire and Rescue
Services, who was present to answer any questions.
The proposed COMAR amendments revise the regulations for MICRB to update the edition year
of the appropriate instructor standards manual, change certain instruction methods, and make
minor style and language changes. Ms. Van Orden recommended that the Maryland Higher
Education Commission approves for publication the proposed amendments to the Maryland
Instructor Certification Review Board regulations, and authorize MHEC’s attorneys to approve
non-substantive revisions as necessary to conform the proposed regulations to the stylistic and
formatting requirements of AELR and of the Division of State Documents. Commissioner
Seurkamp motioned to approve and Commissioner Brown seconded the motion. The motion
was approved unanimously.
2021-2025 Maryland State Plan for Higher Education Update
Chair Smarick recognized Dr. Dow who gave an update on the 2021-2025 State Plan. Dr. Dow
reported that she made a presentation on the State Plan to the Student Advisory Council and the
Faculty Advisory Council recently. The presentation was well-received, and she was given good
feedback from both Councils. Their feedback will be incorporated into the upcoming draft
(which will focus on the new priorities). The Commission will be advised when the draft is
circulated for public comment, and information on public comment will be shared at the March
meeting. Commissioner Boyd asked about the type of feedback provided by the students. Dr.
Dow answered that one concern regarding student access was preparing students for a college
education. Another concern was the quality of online education and the question of whether or
not it was equitable.
Adjournment
Commissioner Seurkamp made a motion to adjourn and Commissioner McDaniels seconded
the motion. The motion passed unanimously. The meeting adjourned at approximately 1:56
p.m.
4Larry Hogan
Governor
Boyd K. Rutherford
Lt. Governor
Andrew R. Smarick
Chair
James D. Fielder, Jr., Ph. D.
Secretary
MEMORANDUM
DATE: March 24, 2021
TO: Maryland Higher Education Commissioners
FROM: Donna Thomas, Director, Office of Student Financial Assistance
SUBJECT: Final Adoption of Amendments to COMAR Financial Aid Regulations –
Richard W. Collins III Leadership with Honor Scholarship Program
On November 18, 2020, the Commission approved for publication in the Maryland
Register proposed amendments to the regulations for the Richard W. Collins III Leadership with
Honor Scholarship Program. The purpose of these amendments is to clarify the definition of
part-time enrollment and alter application deadline dates. The proposed regulations were
published in the Maryland Register on January 15, 2021. The public comment period for the
regulations ended on February 15, 2021, and no public comments were received.
The proposed amendments to the regulations are ready for the Commission’s final
adoption. The amendments will become effective 10 days after notice of the final adoption is
published in the Maryland Register.
RECOMMENDATION: It is recommended that the Commission approves for final adoption
the attached amendments to the regulations for the Richard W. Collins III Leadership with Honor
Scholarship Program.
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
5Title 13B MARYLAND HIGHER EDUCATION
COMMISSION
Subtitle 08 FINANCIAL AID
Chapter 11 Richard W. Collins III Leadership with Honor Scholarship Program
Authority: Education Article, §§11-105(u), 18-204(c), and 18-605(e), Annotated Code of Maryland
.02 Definitions.
A. In this chapter, the following terms have the meanings indicated.
B. Terms Defined.
(1) – (4) (text unchanged)
(5) “Full-time” means enrollment at an eligible institution in:
(a) At least 12 credits per semester in a certificate or undergraduate degree program; or
(b) At least 9 credits per semester in a graduate certificate, graduate degree, or doctoral degree program.
(6) – (7) (text unchanged)
(8) “Part-time” means enrollment at an eligible institution in:
(a) At least 6 credits but less than 12 credits per semester in a certificate or undergraduate degree program;
or
(b) At least 6 credits but less than 9 credits per semester in a graduate certificate, graduate degree, or
doctoral degree program.
[(8)] (9) (text unchanged)
[(9)] (10) (text unchanged)
.03 Student Eligibility.
A. (text unchanged)
B. An applicant is eligible for a scholarship if the applicant:
s(1) Is enrolled full-time or part-time at an eligible institution;
(2) Is a member of a ROTC program;
(3) Has been identified by the institution as a minority student or a student who is a member of another group
historically underrepresented in Reserve Officer Training Corp (ROTC) programs;
(4) Has been determined to be eligible for in-State tuition by the institution; and
(5) Timely files an application and any required supporting documentation with the Office.
.04 Application Process.
A. (text unchanged)
B. Form of Application.
(1) An applicant shall apply and submit a Free Application for Federal Student Aid (FAFSA) by [July15] April 1.
(2) If the applicant is ineligible to submit a FAFSA, but qualifies for in-State tuition under Education Article,
Title 15, Annotated Code of Maryland, the applicant shall submit a Maryland State Financial Aid Application
(MSFAA) by [July 15] April 1.
C. – D. (text unchanged)
E. Time of Submission.
(1) An application and FAFSA or MSFAA received by the Office by April 1 will have priority consideration for
an award.
(2) If funds are available, an application and FAFSA or MSFAA received by the Office after April 1, but no later
than July 15, may be considered for an award.
(3) An application and FAFSA or MSFAA received by the Office after July 15 is untimely and may not be
considered.
F. – G. (text unchanged)
6Larry Hogan
Governor
Boyd K. Rutherford
Lt. Governor
Andrew R. Smarick
Chair
James D. Fielder, Jr., Ph. D.
Secretary
MEMORANDUM
DATE: March 24, 2021
TO: The Maryland Higher Education Commission
FROM: Education Policy Committee, Maryland Higher Education Commission
SUBJECT: Strayer University’s Request for Waiver of Full-Time Faculty Definition
Strayer University ("Strayer") has submitted a request for a waiver from the definition of full-
time faculty consistent with the Commission’s "Requirements for Authorization of Out-of-State
Degree-Granting Institutions to Operate in Maryland," specifically COMAR 13B.02.01.16E.
There are two elements regarding faculty that are required for MHEC to approve an out-of-state
institution to operate in Maryland: (1) At least 1/3 of the classes offered shall be taught by full-
time faculty of the parent institution and (2) meeting the specified definition of full-time faculty
found in COMAR (also listed below).
The Education Policy Committee reviewed the materials presented in this memo and discussed
this matter at the February 22, 2021, committee meeting. Representatives from Strayer
University provided public comment and committee members asked questions.
RECOMMENDATION: It is recommended that the Commission deny Strayer University’s
waiver of the definition of full-time faculty as provided for in the Maryland Higher Education
Commission’s "Requirements for Authorization of Out-of-State Degree-Granting Institutions to
Operate in Maryland." Strayer has not demonstrated that its “unique role, scope, and mission…
requires a waiver in order for the institution to operate in Maryland,” pursuant to the
requirements of COMAR 13B.02.01.16E(2).
Upon review of the University’s renewal application to continue operations in Maryland by
MHEC staff, it was discovered that the University was out of compliance in meeting the 1/3
full-time faculty standard (by not meeting the COMAR definition of full-time faculty) and
subsequently requested the waiver. Strayer’s renewal application remains active until a
determination regarding this request is resolved. While Strayer provided commentary on its
mission, role and scope, it is not clear what about its mission, role and scope is unique that
merits an exemption to the definition of full-time faculty.
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
7MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 2 of 11
Staff Analysis
Regulatory Background
Commission records indicate that faculty waivers have been granted to Lesley University
(2017), LaSalle University (2015), and Walden University (2013); none of these institutions
currently operates in Maryland. Prior to Walden’s 2013 request, such a waiver request had not
been brought forth for action by the Commission for many years. Records also indicate that only
five other full-time faculty waivers have been approved dating back to 1996, to the following
institutions: Sojourner Douglass College (now closed), University of Maryland Global Campus
(formerly University of Maryland University College (UMUC)), University of Phoenix (no
longer operating in Maryland), Baltimore Hebrew University (merged with Towson University),
and Binah Institute of Advanced Judaic Studies for Women.
The definition of full-time faculty in COMAR 13B.02.01.03 from which Strayer seeks a waiver
is as follows:
(10) Full-time faculty member means an employee:
(a) Whose primary professional responsibility is instruction, research, scholarship, or
service;
(b) Who performs those functions normally expected of a full-time faculty member at an
institution of higher education, including curriculum development, student advising,
and institutional service;
(c) Who is employed on an annual or renewable contract of at least 9 months long that
stipulates an annual salary; and
(d) Who is not employed full-time by another employer.
Per COMAR 13B.02.01.16, an out-of-State institution may apply to the Commission for a
waiver from the definition of "full-time faculty member.” In order to obtain a waiver, an
institution shall demonstrate that the unique role, scope, and mission of the institution require a
waiver in order for the institution to operate in Maryland.
Institutional Background
Strayer is a national, for-profit university headquartered in Washington, D.C., and is licensed to
operate by the Higher Education Licensure Commission of the District of Columbia. Strayer is
accredited by Middle States Commission on Higher Education and has been operating in
Maryland for about two decades. Strayer was last granted extended approval to operate in
Maryland in 2015 through August 31, 2020.
Strayer operates five campuses in Maryland: Anne Arundel, Owings Mills, Prince George’s
(Parent Campus), Rockville, and White Marsh. The campuses offer 17 open-access programs
ranging from the associate to master’s level, with each campus offering primarily the same
instructional programs; two programs - the M.S. in Healthcare Services Administration and
Master of Public Administration - are not offered at Owings Mills and White Marsh.
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
8MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 3 of 11
Additionally, the Bachelor of Science in Information Systems is in teach-out at all five
campuses.
Institutional Mission Analysis
Strayer University’s website provides the institutional mission:
Through exceptional service and our personal commitment to student success, we enable
students to obtain a valuable education and change their lives, starting the day they enroll. 1
Additionally, Strayer’s core values include educational access for a diverse student body;
academic quality with rigorous, engaging, and professionally relevant academic programs and
experiences; student success; and customer service.
Institutional Justification for Waiver
Strayer reports that a shift in student preference resulted in the institution’s need to shift its
operational strategy, re-aligning its use of real estate and human capital to focus more on
providing services, as opposed to explicit in-person instruction, at its campus locations. 2
Consequently, faculty are hired for the purpose of instruction. Staff at a specific campus
location are hired to provide specialized student services such as enrollment, financial advising,
and academic advising. Strayer relies on this shift in its operational strategy to explain why
faculty resources are not bound by long term contracts, but rather faculty are hired as student
demand dictates with adjunct faculty hired on renewable contracts. Strayer’s full-time faculty
are employed at-will with an annual salary and are treated as regular employees; they are not
subject to contracts, renewable or otherwise. 3
Strayer stated that the dynamic nature of education and its global environment requires that the
institution conduct a constant review of short and long-term goals and objectives and progress
toward achieving those goals. 4 Strayer is committed to continuous improvement through
rigorous periodic evaluation of progress toward achieving its mission and goals, 5 offering
academic programs in areas in which it has academic expertise and for which significant student
demand exists. As such, course-by-course demand at Strayer cannot be projected as easily over
the long-term in comparison to traditional brick and mortar institutions where long-term demand
is much easier to map. In order to meet the significantly more elastic demand at the course-level,
Strayer asserts its need to ensure that the supply of faculty members is equally as elastic to
ensure that supply meets demand. Lastly, Strayer added that the University places great value on
faculty who stay up to date in their professional field – this means that many faculty may also be
employed elsewhere in addition to their teaching duties at Strayer. These faculty, then, do not
1
Strayer University. Mission. Retrieved from http://strayer.smartcatalogiq.com/2020-2021/Catalog/General-
Information/Mission
2
Strayer University, Supplemental Response (9/23/2020); page 4
3
Strayer University, Supplemental Response (9/23/2020); page 4
4
Strayer University, Supplemental Response (9/23/2020); page 3
5
Strayer University. Institutional Philosophy. Retrieved from http://strayer.smartcatalogiq.com/2020-
2021/Catalog/General-Information/Institutional-Philosophy
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
9MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 4 of 11
conduct activities that, in many cases are conducted by other specialized organs at the
University. 6
Finding: In each request for documentation, Strayer reiterated its statement from its original
submission: its unique role and scope as rooted in its mission statement. “We provide
postsecondary education to a diverse set of students, including a racially and ethnically diverse
population with a wide age range.” 7 MHEC staff does not find evidence of a unique mission that
merits a waiver of the definition of full-time faculty. Instead, Strayer provides arguments
regarding operational motivations for requesting the waiver.
Additional Information and Considerations
Current Status of Full-time Faculty
None of the faculty currently employed by Strayer meet the definition of full-time faculty as
specified in COMAR 13B.02.01.03. A summary is provided in the table below.
Table 1
COMAR Definition Summative Commentary
(10) "Full-time faculty member" means an This requirement is met, as COMAR uses the
employee: term "or." Faculty are engaged only in instruction
(a) Whose primary professional responsibility is
instruction, research, scholarship, or service;
(b) Who performs those functions normally This requirement is not met, as COMAR uses the
expected of a full-time faculty member at an term "and." All faculty are engaged in student
institution of higher education, including advising. Some faculty may participate in
curriculum development, student advising, and curriculum development. None are engaged in
institutional service; research or institutional service.
(c) Who is employed on an annual or renewable This requirement is not met. No faculty are
contract of at least 9 months long that stipulates employed on contract. Faculty are employed at
an annual salary; and will.
(d) Who is not employed full-time by another In its previous response, Strayer indicated that its
employer. full-time faculty may hold full-time employment
elsewhere. In its February 10th response (page 1),
the institution stated "Full-time faculty at Strayer
satisfy the first and last element because their
primary responsibility is instruction and they are
not employed full-time elsewhere."
6
Strayer University Request for Faculty Waiver, (8/4/2020), Page 2
7
Strayer University Request for Faculty Waiver, (8/4/2020), Page 2; Supplemental Response (9/23/2020), Page 3;
Supplemental Response (2/10/2021)
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
10MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 5 of 11
A review of Strayer University’s request indicated that the institution employs faculty who are
full-time employees of the University by Strayer’s definition; faculty are not full-time by
COMAR’s definition in that faculty do not engage in scholarship or service, faculty are not
provided contracts as full-time employees, and are not prohibited from other employment (with
the exception of conflicts of interest). Faculty are at-will employees. 8
The job description for full-time faculty provided by Strayer indicated the following
responsibilities:
• Provides coaching and mentoring to students, approaching student challenges with
empathy and competence.
• Faculty takes an active leadership role in the Strayer University learning community,
offering feedback on the curriculum and working collaboratively with other employees
and departments to serve Strayer students.
• In addition, full-time faculty may
o Offer feedback regarding curriculum effectiveness;
o Suggest curriculum modifications and enhancements.
o Work collaboratively with other employees to promptly and satisfactorily resolve
student issues.
o Mentor less experienced members of the Strayer University faculty.
o Attend faculty trainings and meetings as required.
With the exception of the four programs highlighted in Table 2, Strayer’s faculty are employed
by the University full-time with the sole purpose of instruction and instructional support of its
students. Strayer emphasized the desire to employ faculty who are current in the profession; as
such, faculty may be employed elsewhere in addition to their teaching duties.
In an email dated September 24, 2020, Strayer’s representative stated that a full-time faculty
member must teach 5 courses in each of the winter, spring, and fall quarters, with the option to
also teach in the summer quarter (not required). Each of Strayer’s courses is 4.5 quarter credit
hours; full-time faculty need to teach 22.5 quarter credit hours in each of the 3 referenced
quarters or an aggregate 67.5 credit hours annually. Below is the list of programs proposed in
the renewal application and the percentage of full-time* instructors in each program (highlighted
programs do not meet 33% full time requirement).
8
Strayer University, Supplemental Response (2/10/2021); page 1
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
11MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 6 of 11
*Strayer University defines “full-time faculty” by the number of courses taught. None of
Strayer’s faculty meet the definition of full-time faculty as stated in COMAR 13B.02.01.03.10.
Table 2
Program % of Full-Time
Instructors*
Master of Science in Human Resource Management 16.7%
Master of Science in Accounting 41.7%
Master of Business Administration 60.0%
Master of Education 0%
Master Science in Information Systems 75.0%
Master of Health Services Administration 0%
Master of Public Administration 16.7%
Bachelor of Business Administration 55.0%
Bachelor of Science in Accounting 40.0%
Bachelor of Science in Information Systems* 45.0%
Bachelor of Science in Information Technology 42.5%
Associate of Arts in Accounting 45.0%
Associate of Arts in Acquisition and Contract Management 40.0%
Associate of Arts in Business Administration 60.0%
Associate of Arts in Information Systems 55.0%
Associate of Arts in Information Technology 50.0%
Associate of Arts in Marketing 45.0%
Diploma in Acquisitions and Contract Management 41.7%
“Designated Faculty” and Roles and Responsibilities
Per COMAR 13B.02.01.16, after an institution demonstrates that the unique role, scope, and
mission of the institution require a waiver in order for the institution to operate in Maryland
(which MHEC staff contends has not been met), the institution shall designate by name the
faculty members whose primary responsibility is instruction, scholarship, research, or service
who will perform the duties normally required of full-time faculty; and, document that
designated faculty members substantially participate in the development or implementation of
one or more of the following activities at the institution requesting the waiver:
(i) Academic programs,
(ii) Professional programs,
(iii) Research programs,
(iv) Service programs,
(v) Admission or admission policies,
(vi) Academic advising,
(vii) Faculty appointments, or
(viii) Institutional governance
According to the job description provided by Strayer, and as noted previously, faculty are
engaged in academic programs, professional programs, academic advising and institutional
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
12MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 7 of 11
governance. Strayer University asserts that all of its faculty have instruction as their primary
responsibility:
In that sense, all of the faculty that are listed in our faculty reports
as part of our renewal are “Designated Faculty.” All Designated
Faculty perform instruction and as such, from a certain point of
view, all of them substantially participate in the provision of
academic programs because without them, there would be no
academic programs. All Designated Faculty also conduct academic
advising as evidenced by the attached full-time faculty job
description. 9
At Strayer, the applicable tasks of full-time faculty (as described in COMAR) are primarily
performed by other people who are specialized to do that task. The University stated that it
creates full-time faculty in the aggregate by putting people and services together in a way that it
believes is a more efficient model for its offerings. Faculty at Strayer are primarily tasked with
teaching; though faculty may opt to engage in other activities, they are not required to do so.
Specifically, “all of the faculty that are listed in our faculty reports as part of our renewal are
‘Designated Faculty.’ No specific faculty members at Strayer have as their primary
responsibility scholarship, research, or service.” 10
The creation of new programs, materials, and content are done by dedicated teams of academic
curriculum specialists and subject matter experts. Faculty have the option to participate in the
creation or updating of curriculum development, but they are not required to participate.
As related to research, Strayer is not a research institution; therefore, faculty do not engage in
research. The institution’s basic Carnegie Classification is “Special Focus Four Year: Business
& Management Schools.” 11
As related to duties performed by faculty, Strayer provided the following key arguments in
support of its faculty waiver request:
As an open access institution, admissions policies are set by the University’s Board of
Trustees and the University President’s office. Changes to the general admissions
policies rarely occur. Implementing these policies is handled by operations teams and
faculty do not participate in admissions decisions.
9
Strayer University, Supplemental Response (9/23/2020)
10
Strayer University, Supplemental Response (9/23/2020); page 1
11
The Carnegie Classification of Institutions of Higher Education. Retrieved from
https://carnegieclassifications.iu.edu/lookup/view_institution.php?unit_id=430184&start_page=lookup.php&clq=%
7B%22ipug2005_ids%22%3A%22%22%2C%22ipgrad2005_ids%22%3A%22%22%2C%22enrprofile2005_ids%2
2%3A%22%22%2C%22ugprfile2005_ids%22%3A%22%22%2C%22sizeset2005_ids%22%3A%22%22%2C%22b
asic2005_ids%22%3A%22%22%2C%22eng2005_ids%22%3A%22%22%2C%22search_string%22%3A%22straye
r+university%22%2C%22level%22%3A%22%22%2C%22control%22%3A%22%22%2C%22accred%22%3A%22
%22%2C%22state%22%3A%22%22%2C%22region%22%3A%22%22%2C%22urbanicity%22%3A%22%22%2C
%22womens%22%3A%22%22%2C%22hbcu%22%3A%22%22%2C%22hsi%22%3A%22%22%2C%22tribal%22
%3A%22%22%2C%22msi%22%3A%22%22%2C%22landgrant%22%3A%22%22%2C%22coplac%22%3A%22%
22%2C%22urban%22%3A%22%22%2C%22community%22%3A%22%22%7D
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
13MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 8 of 11
Faculty hiring is done through centralized HR and Recruiting functions. These HR and
Recruiting functions carry out the credentialing requirements necessary to ensure compliance
with state regulations. Unlike faculty at traditional institutions, Strayer faculty do not receive
tenure, so faculty appointment decisions do not play a critical role, the way they may at a
traditional institution.12
Professional Activities
The primary duty of Strayer faculty is to teach; faculty are not required to meet certain
benchmarks in their professional or academic development. Strayer University has a
professional development fund that permits faculty to attend academic conferences and assist in
their professional development.
Student Population
Based on enrollment data provided with the renewal application to operate in Maryland, Strayer
enrolls over 6,000 Maryland students, as depicted in Table 3 below.
Table 3
Data retrieved from Student Enrollment Data Report, September 1, 2018 - August 31, 2019
% part-
Full Part- % part- % total
Full Time Part-Time time Total PT Total
Campus Time Time time Grad P/T
Undergrad Undergrad Undergrad enrollment Enrollment
Grad Grad enrollment enrollment
enrollment
Owings Mills 46 691 94.0% 28 102 78.0% 793 867 91.5%
Anne Arundel 114 588 83.8% 49 127 72.2% 715 878 81.4%
Prince George’s 200 1,596 88.9% 130 293 69.3% 1,889 2,219 85.1%
White Marsh 72 802 91.8% 5 126 96.2% 928 1,005 92.3%
Rockville 70 366 83.9% 49 77 61.1% 443 562 78.8%
Maryland campuses - Total part-time enrollment 4,768 5,531 86.2%
Strayer indicated that it serves a mature student population with an overwhelming majority of
students attending part-time. Strayer postulated that the more mature status of its students and
their needs means that they do not require the same services that are required at a traditional
university and that its students chose Strayer not to publish research papers in academic
journals; students are coming to Strayer for practical knowledge about how to run a business.
According to Strayer, the faculty requirements set forth in COMAR are “more appropriate for
traditional institutions where younger students have the time to do those kinds of things. As
such, requiring our faculty to support those kinds of endeavors and to comport with such
requirements would be incongruous with the demands of our student body.” 13
12
Strayer University Request for Faculty Waiver, (8/4/2020), page 5
13
Strayer University, Supplemental Response (9/23/2020); page 3
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
14MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 9 of 11
In its February 10, 2021 response, Strayer provided the following data to support its claim about
student preference for online classes:
As shown in the chart below, during the spring 2019, summer 2019,
fall 2019, and winter 2020 quarters 24,4341* Maryland students
assigned to a Maryland campus were registered for courses, of
which 21,211 or eighty-six percent (86%) took online courses.
However, as a point of clarification, our references to online
enrollment at 93% are referring to the university as a whole.
Table 4
*Note this is the aggregate number over the four referenced quarters, which includes that some
students were enrolled in each quarter.
Middle States Accreditation Standards
Strayer’s operational strategy is permissible as determined by its continued accreditation by
Middle States. In compliance with Middle States standards, 14 Strayer employs departments to
conduct many of the services and functions described in COMAR 13B.02.01.16. Middle States
requires that the institution “commits to student retention, persistence, completion, and success
through a coherent and effective support system sustained by qualified professionals, which
enhances the quality of the learning environment, contributes to the educational experience, and
fosters student success (Middle States Commission on Higher Education, Standard IV – Support
of the Student Learning Experience). 15
Middle States specifically allows for “student learning experiences that are designed, delivered,
and assessed by faculty (full-time or part-time) and/or other appropriate professionals” (Middle
States Commission on Higher Education, Standard III - Design and Delivery of the Student
Learning Experience).
Faculty Requirements from the D.C. Higher Education Licensure Commission
14
Middle States Commission on Higher Education. Standards for Accreditation and Requirements of Affiliation.
https://www.msche.org/standards/#standard_7
15
Middle States Commission on Higher Education. Standards for Accreditation and Requirements of Affiliation.
https://www.msche.org/standards/#standard_7
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
15MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 10 of 11
Per the Washington D.C. Higher Education Licensure Commission’s regulations 8004.8 Faculty,
there is no established ratio for the full-time faculty complement, nor do the regulations require
that faculty engage in activities outside of teaching and professional development:
8004.8 Faculty. In order to qualify for a license, a postsecondary degree granting
educational institution shall demonstrate that:
(a) The faculty possess academic, scholarly, and teaching qualifications generally
recognized as appropriate to their respective positions;
(b) There are a sufficient number of full time or part time academic faculty appointments
to ensure continuity and stability of the educational program at each location where each
program is offered, as well as to provide adequate educational association between
students and faculty;
(c) Full-time faculty devotes a majority of their professional time as employees of the
postsecondary degree granting educational institution as assigned;
(d) The teaching assignments of faculty members permit adequate opportunity for
classroom preparation, professional growth, and other appropriate functions;
(e) Fair, clear, and adequate procedures for the appointment, promotion, evaluation,
award of tenure, if applicable, disciplining, and dismissal of faculty members are in
place;
(f) Adequate policies and procedures to protect academic freedom are in place; and
(g) An opportunity exists for the faculty to participate in the planning of and evaluation
of the curriculum.
Assessment of Online Learning 16
Students enrolled in online courses at Strayer are offered both summative and formative
assessment opportunities, at the same number and rigor as on-ground courses (i.e., in-person
courses). Not all Strayer courses are offered on-ground; however, courses that are available in
both modalities offer the same curriculum, including learning outcomes. Strayer summative
assessments are designed to measure student mastery of the course learning objectives, while
formative assessments are intended to support student learning as they progress through the
course to help them succeed on their summative assessments. Like Strayer on-ground courses,
the majority of the summative online assessments are performance-based and include rubrics.
Examples include portfolios, presentations, case studies, client reports, executive summaries,
academic research papers, and essays. Formative assessments may include quizzes, labs, journals
and discussions. Moreover, when on-ground classes were held prior to the commencement of the
COVID-19 pandemic, students in on-ground courses were required to submit their summative
assessments online and also complete their formative assessments online. In assessing student
16
Summary from Strayer University, Supplemental Response (2/10/2021)
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
16MHEC Recommendation: March 24, 2021
Strayer University, Faculty Waiver Request Page 11 of 11
coursework, faculty evaluate student work using the associated assessment rubric. Due to the
importance of faculty feedback, faculty provide rich feedback in written and/or video format
through the Learning Management System (LMS). Faculty review each rubric criteria, assigning
appropriate points based on student mastery level of the criteria. For objective assessments,
predetermined correct responses, as identified by the faculty/subject matter expert and
curriculum team, are entered into the assessment tool prior to the beginning of a term. Upon
student completion of an objective assessment, scoring is automatically completed and the score
reflected in the LMS gradebook.
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.gov
17Larry Hogan
Governor
Boyd K. Rutherford
Lt. Governor
Andrew R. Smarick
Chair
James D. Fielder, Jr., Ph. D.
Secretary
Maryland Higher Education Commission
2021 Meeting Dates
The Maryland Higher Education Commission (MHEC) is Maryland’s higher education
coordinating board responsible for the management of statewide financial aid programs and the
establishment of statewide policies for public and private colleges and career schools to support
students’ postsecondary pursuits.
Meeting Dates and Locations
January 27, 2021 July 28, 2021
(if needed)
February 24, 2021 August 25, 2021
(if needed)
March 24, 2021 September 22, 2021
10:00am to 4:00pm
April 28, 2021 October 27, 2021
May 26, 2021 November 17, 2021
*Please note date change.*
June 23, 2021 December 15, 2021
*Please note date change.*
All Commission meetings will be held on the 4th Wednesday of each month from 1:00pm to
4:00pm, with certain exceptions. Meetings in 2021 will be conducted via video
teleconference (GoToMeeting), unless otherwise noted.
Dates and times are subject to change.
http://www.mhec.maryland.gov/About/Pages/Meetings.aspx
MARYLAND HIGHER EDUCATION COMMISSION
6 N. Liberty Street • 10th Floor • Baltimore, MD 21201
T 410.767.3300 • 800.974.0203 • F 410.332.0270 • TTY for the Deaf 800.735.2258 www.mhec.maryland.govYou can also read
