The California State Auditor (CSA) apparently raised questions about use of "Online Program Management" companies (OPMs) to provide online instruction UC campuses. Since online instruction came into use, there have been commercial firms that provide instruction and have internet platforms for doing so. The Auditor apparently was concerned about who was doing the instruction as opposed to the method of delivery. The systemwide Academic Senate conducted a review in response.
Much of Senate review seems focused on "transparency" about who was doing the instruction, i.e., disclosing whether the instructor was from UC or from the outside OPM. But there seems to be a larger issue about outsourcing teaching. While much is said in the review about assuring quality, the review seems to sidestep the issue of outsourcing instruction. This avoidance seems surprising given the sometimes excessive concerns at UC and at the UC campuses about protecting "brands." Do we really want to have students, who have competed to be admitted to a UC campus and program, be taught by outside OPM instructors? Is that what our students thought they would be getting when they applied?
That's the unaddressed Elephant in the Zoom.
We reproduce below the cover letter of the review dated Nov. 20 to UC Provost Newman from Academic Council Chair Palazoglu. However, as noted, the issue raised in the Nov. 5 letter to Chair Palazoglu from Katheryn Niles Russ, Chair, Davis Division of the Academic Senate, Professor of Economics, University of California, Davis, seems to have been neglected in the final report:
...UGC [Undergraduate Council] highlights their concern that the California State Auditor’s (CSA) report revealed that OPM-run courses were misrepresented as UC offerings, and wonders which departments are already using OPMs, how these arrangements benefit students, and what circumstances truly require OPM-hired instructors versus UC faculty and instructors. Similarly, CAES [College of Agricultural and Environmental Sciences] questions what prompted the audit by the CSA and asks what the perceived benefits of hiring an outside company to manage these courses rather than vetting and hiring lecturers to manage the course internally are. CAES also wonders whether every OPM instructor should be reviewed and appointed as a lecturer to ensure that they meet UC standards, and whether the interim policy reflects a move to start offering third-party online courses for students for credit...
Source: https://senate.universityofcalifornia.edu/_files/reports/council-chair-to-provost-presidential-opm-policy.pdf (p. 9)
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November 20, 2025
Katherine S. Newman
Provost and Executive Vice President, Academic Affairs
Re: Systemwide Senate Review of Interim Presidential Policy for the University of California’s Use of Online Program Management Companies
Dear Provost Newman,
As requested, I distributed for systemwide Academic Senate review the Interim Presidential Policy for UC’s Use of Online Program Management Companies (OPMs). All 10 Academic Senate divisions and two systemwide Senate committees (UCEP [University Committee on Educational Policy], UCFW [University Committee on Faculty Welfare]) submitted comments. These were discussed at the Academic Council’s November 17, 2025 meeting, and the compiled feedback is attached for your reference.
The policy responds to recommendations from the California State Auditor (CSA) concerning UC’s use of OPMs. It establishes systemwide standards to uphold academic integrity, transparency, and compliance with federal and accreditation requirements in OPM partnerships. The policy requires that students be informed when courses are taught by non-UC instructors employed by OPMs and that instructor affiliations and credentials be clearly disclosed. It prohibits enrollment-based financial incentives, outlines expectations for student interaction and assessment, and provides guidance for working with accredited and non-accredited affiliates. The policy currently applies to graduate-level programs but may extend to undergraduate programs as UC expands online course offerings.
Senate reviewers expressed general support for the intent of the interim policy to ensure academic integrity, transparency, and compliance with federal and accreditation standards in UC’s partnerships with OPMs. They viewed the policy as an appropriate and necessary response to the CSA’s findings and an important step toward establishing consistent systemwide standards to address identified risks. However, reviewers found that the policy would benefit from greater clarity and detail regarding faculty oversight, intellectual property, and implementation mechanisms.
Policy Scope and Definitions: Reviewers requested clarification of the policy’s scope, noting inconsistent references to courses, programs, and divisions, as well as conflation of terms such as “schools,” “divisions,” and “Extension.” They recommended aligning terminology, clearly distinguishing between instructional and non-instructional OPM activities, and defining the policy’s coverage as UC expands into undergraduate online instruction.
Senate Oversight: Reviewers emphasized that Senate review and continuing faculty oversight must apply to all OPM-affiliated courses and programs. UCEP specifically noted the need to align OPM-related instructional hiring with Senate Regulations 750A and 800A, which govern faculty appointments and course approval. The committee also highlighted variation in Professional and Continuing Education hiring practices across campuses and recommended stronger coordination and oversight to ensure consistency and academic standards.
Instructor Qualifications and Transparency: Faculty supported disclosure of instructor affiliation and credentials but questioned the usefulness of fine distinctions among UC-employed and UC-contracted instructors. Several noted that professional programs may appropriately prioritize industry experience over traditional academic credentials.
Student Data Privacy and Security: There was strong concern about protecting student information handled by third-party vendors. Reviewers urged that all OPM contracts undergo IT security and privacy review consistent with UC data protection policies and that data retention and recovery protocols be clearly specified.
Intellectual Property and Course Ownership: Reviewers sought explicit assurance that instructional materials developed by UC instructors remain UC or faculty property and that UC retains control over the use and withdrawal of content hosted by OPM platforms.
Course Evaluation: Reviewers supported student evaluations but advised aligning them with UC’s established evaluation practices, supplementing them with peer or faculty review and periodic program-level assessments similar to academic program reviews. UCEP recommended that evaluations include items addressing the adequacy of online modality support for students.
Compliance, Accountability, and Transparency: While reviewers supported the prohibition on incentive-based compensation, they found enforcement provisions vague and recommended clearer accountability for campuses and vendors, defined consequences for violations, and greater transparency into UC’s OPM relationships. Many suggested a systemwide registry or regular reporting of contracts, financial terms, and oversight outcomes, and encouraged UC to build internal capacity for online program management to safeguard academic quality.
Overall, Senate reviewers support the policy’s goals and urge UCOP to strengthen provisions related to faculty oversight and appointment processes, clarify terminology and scope, specify data and intellectual property protections, and establish robust enforcement and transparency mechanisms before issuing a final policy.
Thank you for the opportunity to opine. Please do not hesitate to contact me if you have any questions.
Sincerely,
Ahmet Palazoglu
Chair, Academic Council
cc: Academic Council, Director of Academic Planning and Policy Corona, Senate Division Executive Directors, Senate Executive Director Lin
Source: https://senate.universityofcalifornia.edu/_files/reports/council-chair-to-provost-presidential-opm-policy.pdf (pp. 1-3)
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