Why one useful pedagogical framework should not become shorthand for accessibility, inclusive teaching, and everything we value in quality online course design
Lately, I have been hearing Universal Design for Learning (UDL) invoked more and more often in conversations about accessibility. I have also seen UDL training emphasized in professional development curricula and promoted by online directors, instructional designers, and teaching and learning professionals as though it were a sufficient response to accessibility, or as though UDL expertise could substitute for accessibility knowledge and remediation skills.
The question is no longer simply who owns the content. The question is: Who owns the learning experience?
In Part 1 of this series, I described a troubling development that has begun to emerge in conversations with instructional designers, faculty developers, online learning leaders, and quality reviewers across SUNY: asynchronous online courses in which the learning management system (LMS) contains little more than a syllabus, a few announcements, and a link to a publisher platform where nearly all of the instructional activity takes place.
This is not an argument against publisher platforms or the valuable instructional resources they provide. Nor is it an argument that all teaching and learning activity must occur within the LMS. External tools can enrich online learning enormously. The concern arises when the institution’s online course becomes little more than an entry point to a commercially developed learning experience, with limited evidence of intentional course design, instructor presence, meaningful interaction, or institutional oversight.
In Part 1, I suggested that the canary is singing. Here, I want to examine what that warning might mean for institutions and what we can do about it.
What Is an Online Course?
For nearly thirty years, I thought higher education had answered this question.
An online course is not simply a collection of digital content. It is an intentionally designed educational experience. It reflects the expertise of the instructor. It creates opportunities for learners to interact with ideas, with one another, with their instructor, and with the institution itself. It provides context, guidance, feedback, reflection, interaction, community, support, and belonging.
These are not arbitrary expectations. They are grounded in decades of scholarship and practice, including the Community of Inquiry framework (Garrison et al., 2000), which emphasizes the interrelationship of social, teaching, and cognitive presences in meaningful online learning experiences.
The LMS is not simply a repository for files. It is the institutionally supported learning environment where these experiences can be brought together. External platforms can be valuable components of that environment, but they should support rather than displace its educational purpose.
Or at least, that is how it should work.
Increasingly, however, I worry that for some courses the LMS has become little more than a hallway leading students somewhere else. And that seemingly subtle shift carries consequences far beyond instructional design.
Eight Institutional Risks We Can No Longer Ignore
1. Pedagogical Risk: When Content Delivery Replaces Teaching
The first thing we risk losing is not content. It is teaching.
Publisher platforms can provide high-quality content, assessments, simulations, adaptive learning activities, and automated feedback. These can be enormously useful instructional resources. But when they constitute nearly the entire learning experience, without meaningful instructional design and facilitation by the faculty member, we risk reducing online education to content consumption and assessment completion.
Teaching involves much more than providing information and measuring whether learners can reproduce it. Faculty contextualize ideas, connect concepts, identify misconceptions, pose questions, challenge assumptions, encourage reflection, facilitate dialogue, and help learners construct understanding.
When these responsibilities are delegated almost entirely to preconfigured learning pathways and automated assessments, the instructor’s role can become primarily administrative: providing access, monitoring completion, and recording grades.
There is also an epistemological dimension to this concern. Many publisher platforms are organized around predetermined content sequences, correct answers, and automated measures of mastery. Those approaches can be appropriate for certain learning objectives. But not all learning can be measured or demonstrated in the same way. Learners also need opportunities to question, argue, discuss, support, defend, interact, collaborate, test, interpret, apply, evaluate, construct, and challenge thinking and assumptions.
My concern is not that publisher platforms necessarily prevent those experiences. It is that they cannot be assumed to provide them simply because they offer a comprehensive package of instructional materials.
Faculty expertise and pedagogical intentionality must remain central to the learning experience.
2. Learner Experience Risk: When Students Lose Their Connection to the Institution
Learners do not simply enroll in courses. They enroll in institutions.
That institutional relationship matters. Learners should experience their online courses as part of a coherent educational environment where they can connect with faculty, peers, academic support services, libraries, accessibility resources, and the broader learning community.
When most instructional activity takes place in a separate commercial environment, that connection can become less visible. Online Learners may experience their course primarily through the publisher’s interface, content sequence, assessments, and automated feedback, with limited opportunities to engage with their instructor or classmates.
This can also introduce questions of equity and affordability. Some publisher platforms require proprietary access codes or subscriptions that may expire at the end of a term. Students may have fewer opportunities to use lower-cost alternatives, previously purchased materials, or open educational resources. Access problems, additional costs, and the inability to retain course materials can become barriers to learning.
These are not inevitable consequences of using publisher courseware. They are risks that institutions need to anticipate, evaluate, and address.
The quality of an online course should be understood not only in terms of the content delivered, but also in terms of the complete experience of being an online learner at the institution.
3. Quality Risk: When We Lose Sight of What Makes an Online Course Effective
For decades, the field of online education has developed research-based practices, quality frameworks, faculty development programs, and instructional design processes to support effective online teaching and learning.
At SUNY, that work is reflected in the OSCQR rubric and process, which support systematic, collaborative review and continuous improvement of online course design and accessibility.
But what happens when institutions no longer consistently apply online-specific expectations for course design, faculty preparation, instructor presence, interaction, feedback, and accessibility?
A syllabus, a welcome announcement, and a link to an external platform do not, by themselves, demonstrate that an online course has been intentionally designed to support effective learning.
At the same time, we must be careful not to confuse LMS activity with instructional quality. An elaborate Brightspace course can still provide a poor learning experience. A course that relies extensively on external tools may be exceptionally well designed and facilitated.
What matters is the quality of the complete learning experience, wherever its components reside.
Institutions need to distinguish between minimum expectations for operating an online course, evidence of effective online teaching, and the more aspirational standards associated with exemplary course design. They also need ways to evaluate all three.
Without a shared understanding of these distinctions, online course quality can become a matter of individual interpretation rather than an institutional commitment.
4. Compliance Risk: When Institutional Obligations Become Difficult to Demonstrate
The regulatory implications deserve particular attention.
Federal distance education regulations distinguish distance education from correspondence education in part through expectations for regular and substantive interaction between students and instructors. Under 34 CFR § 600.2, qualifying interaction must meet specific requirements, including opportunities for substantive engagement initiated by the instructor on a predictable and scheduled basis.
Automated publisher feedback, self-paced quizzes, and student-initiated requests for assistance may contribute to learning, but they do not necessarily satisfy these requirements. Nor does simply posting a link to optional office hours establish that regular and substantive interaction is occurring.
The relevant question is whether the actual course experience meets the applicable regulatory definition, not whether the course uses a particular platform.
Accessibility presents another significant responsibility. The U.S. Department of Justice’s Title II web accessibility rule establishes WCAG 2.1 Level AA as the technical standard for covered state and local government web content and mobile applications, subject to the rule’s applicable requirements, exceptions, and compliance provisions.
Institutions cannot assume that accessibility obligations disappear when required instructional materials or activities are delivered through a third-party platform. They need to evaluate accessibility, address barriers, establish appropriate procurement and contractual expectations, and provide accessible learning experiences.
These issues also intersect with accreditation, institutional policies, student support, and academic quality assurance.
Responsibility cannot simply be outsourced along with the technology.
5. Accountability Risk: When the Institution Cannot Adequately Document the Learning Experience
This is one of the risks that concerns me most because it is discussed so infrequently.
There are a number of documentation and accountability issues that pose risks. First, if most of the teaching, feedback, interaction, and assessment activity lives outside the LMS in the publisher’s environment, the institution may have a much thinner record of what the instructor actually did in the course.
That creates practical problems for instructor evaluation, peer review, student complaint review, audit response, course quality review, and accessibility review.
In this context, Brightspace is not just a delivery tool. It is also part of the institution’s documentary record of the student learning experience.
Accreditation reinforces the importance of institutional evidence. The Middle States Commission on Higher Education’s standards emphasize institutional effectiveness, educational quality, student learning, and the use of evidence to demonstrate that institutional responsibilities are being fulfilled.
Consider what happens when a student raises a concern about the absence of instructor feedback or meaningful interaction. Can the institution reconstruct what occurred? Can it review communications, instructional interventions, feedback, and assessments? Can it determine whether the instructor fulfilled applicable expectations?
External platforms may maintain extensive records, and those records may be entirely adequate if the institution has appropriate access, retention arrangements, and the ability to interpret and use them. But access cannot simply be assumed. Nor should records of clicks, completed assignments, and grades automatically be treated as evidence of meaningful teaching presence or substantive interaction.
The question is not whether all educational activity must reside in Brightspace. It is whether the institution maintains sufficient visibility, access, control, and documentation to fulfill its responsibilities.
When institutions cannot adequately examine or document what students experienced, they may struggle to evaluate quality, respond fairly to concerns, or demonstrate that their own expectations have been met.
6. Institutional Risk: When Academic Ownership and Responsibility Become Blurred
Institutions of higher education are responsible for the education they provide, regardless of the technologies or instructional resources they adopt.
When a commercial platform increasingly determines the content sequence, learning activities, assessments, and feedback students experience, questions arise about who is making the fundamental educational decisions.
What role does the instructor play in shaping the course? What expectations does the academic department establish? What responsibility does the institution retain for reviewing and approving the educational experience? And how are those responsibilities understood across faculty, academic leadership, instructional design, and academic governance?
These questions are not arguments for restricting academic freedom or imposing a single instructional model. Faculty expertise, disciplinary differences, and academic judgment are essential to quality education.
But academic freedom and institutional responsibility are not mutually exclusive. Institutions can respect faculty autonomy while establishing transparent, collaboratively developed expectations for online course quality, accessibility, student engagement, and academic accountability.
What concerns me is the possibility that institutional responsibility becomes so diffuse that no one is clearly accountable for the design and quality of the complete online learning experience.
7. Strategic Risk: When Institutional Capacity Becomes Vendor Dependence
There are also significant long-term strategic implications.
Publisher platforms can offer sophisticated instructional capabilities that would be costly or impractical for individual faculty or institutions to develop independently. Partnerships with external providers can be beneficial and appropriate.
But institutions need to consider the consequences of becoming dependent on those platforms for substantial portions of their online instructional offerings.
What happens when a publisher changes its pricing, licensing terms, accessibility features, product offerings, or technical integrations? What happens when a product is discontinued, a vendor is acquired, or students lose access to materials after a subscription expires?
Can the institution retrieve instructional records and assessment data? Can faculty adapt or replace the learning activities? Can the course continue if the platform becomes unavailable or unaffordable? Are student privacy, data retention, and portability adequately addressed in institutional agreements?
There is also a less visible risk: the gradual erosion of institutional capacity to design and develop online courses.
For decades, institutions invested in faculty development, instructional design expertise, online teaching support, and quality assurance infrastructure. If more courses become dependent on ready-made external instructional environments, those institutional capabilities may receive less attention and investment.
Over time, an institution could find itself increasingly dependent on vendors not only for instructional content and technology, but also for the design of the learning experience itself.
That is a strategic choice, whether institutions recognize that they are making it or not.
8. Leadership Risk: When We Do Not Know What Is Happening in Our Online Courses
Perhaps the most immediate institutional risk is that leaders may not know the extent to which these practices are occurring.
How many asynchronous online courses rely primarily on external publisher platforms? What instructional activity occurs within those environments? How are faculty interacting with students? What evidence exists of regular and substantive interaction? How are accessibility and course quality being evaluated? What records can institutions retrieve when concerns arise?
These are questions that online learning leaders, academic administrators, faculty governance bodies, and institutional quality assurance teams should be able to answer.
But the answers may not be readily available.
It would be a mistake to respond to these concerns by abruptly suspending online courses, restricting the use of publisher resources, or imposing requirements without understanding their consequences. Online education is essential to access, enrollment, institutional sustainability, and the missions of many institutions. Poorly planned interventions could create substantial academic, financial, and organizational harm.
Equally problematic, however, would be ignoring the warning signs because the issues are complex or uncomfortable to address.
Effective leadership begins with understanding what is happening, why it is happening, and what support institutions and faculty need to address it.
Without that understanding, institutions cannot lead intentionally. They can only react.
So Where Do We Go From Here?
I do not believe the answer is to abandon publisher platforms, prescribe a single model of online course design, or assume that faculty who rely on external instructional resources are necessarily providing poor educational experiences.
Nor do I believe the answer is to impose another layer of compliance-oriented course checklists without providing the professional development, instructional design support, time, and resources needed to meet meaningful expectations.
What is needed is a deliberate, institutionally supported approach to understanding and strengthening online course quality.
First, Understand Before Acting
Institutions need a clearer picture of what their online courses actually look like and how they function.
That means examining course design practices, faculty preparation, the use of external platforms, instructor presence, student interaction, accessibility, feedback, assessment, and institutional access to instructional records.
It also means understanding the operational realities: faculty workload, instructional support capacity, enrollment, revenue, program requirements, and the reasons faculty adopt particular resources.
LMS analytics can provide useful information, but they cannot tell the whole story. A meaningful review must examine the complete learning experience, including activity occurring outside the LMS.
Second, Engage the People Who Do the Work
Faculty, instructional designers, faculty developers, online learning leaders, academic administrators, accessibility professionals, technology staff, and students all have important perspectives on this issue.
Faculty governance and, where applicable, collective bargaining considerations must also be part of the process.
The goal should be to understand practices, identify barriers, and develop shared expectations rather than assign blame.
Some faculty may be relying heavily on publisher platforms because they have never had access to meaningful preparation for online teaching. Others may be responding to workload pressures, limited instructional design support, institutional requirements, or the need to rapidly rebuild courses after the pandemic and LMS migration.
Understanding those circumstances is essential to developing responses that are both effective and sustainable.
Third, Establish Clear Expectations for Online Courses
Institutions need to distinguish between minimum requirements for offering an online course, expectations for effective online teaching, and aspirational standards for exemplary online course design.
Those expectations should address instructor presence, meaningful interaction, feedback, accessibility, student support, instructional coherence, and the appropriate use of external tools.
They should also clarify what documentation and institutional access are necessary when instructional activity takes place outside the LMS.
These expectations should be developed collaboratively, grounded in research and effective practice, and flexible enough to accommodate disciplinary differences and varied pedagogical approaches.
Fourth, Invest in Faculty Preparation and Instructional Design Support
Institutions cannot expect high-quality online education without investing in the people and processes that make it possible.
Faculty need opportunities to develop expertise in online pedagogy, course design, facilitation, accessibility, assessment, and the effective integration of instructional technologies.
They also need access to instructional designers and faculty developers who can help them translate pedagogical intentions into meaningful online learning experiences.
This is particularly important for faculty whose first experience teaching online occurred during the pandemic and who may never have participated in the more deliberate preparation processes that existed before it.
Supporting faculty should be understood as an institutional investment in educational quality, not simply an individual professional development responsibility.
Fifth, Make Quality Assurance an Ongoing, Supportive Process
Online course quality should not be treated as a one-time approval or compliance exercise.
Frameworks such as SUNY OSCQR can support formative review, collaborative improvement, and institutionally coordinated approaches to online course quality.
Institutions should use such processes to identify strengths, support faculty, address accessibility and instructional design concerns, and establish a culture of continuous improvement.
Implementation should be phased, adequately resourced, and attentive to academic calendars, enrollment needs, financial realities, faculty workload, and institutional culture.
The objective is not to police online courses. It is to ensure that institutions are fulfilling their educational responsibilities and supporting faculty and students in doing their best work.
Reclaiming the Online Course
For more than three decades, online education has evolved through research, experimentation, technological innovation, faculty development, instructional design, and continuous improvement.
We learned that effective online education requires more than access to content. It requires intentional decisions about how students engage with knowledge, instructors, one another, and the institution.
That accumulated knowledge and experience should not become an unintended casualty of the pandemic, changing technologies, workload pressures, or the convenience of increasingly comprehensive publisher platforms.
We do not need to reject the tools that can enhance online learning. We need to be intentional about how we use them, what responsibilities we delegate, and what responsibilities we retain.
The question is no longer simply who provides the content, hosts the technology, or delivers the assessments.
The question is who takes responsibility for the learning experience.
And for institutions of higher education, that responsibility must remain our own.
References and Resources
Garrison, D. R., Anderson, T., & Archer, W. (2000). Critical inquiry in a text-based environment: Computer conferencing in higher education. The Internet and Higher Education, 2(2–3), 87–105. https://doi.org/10.1016/S1096-7516(00)00016-6
U.S. Department of Justice. (2024). Fact sheet: New rule on the accessibility of web content and mobile apps provided by state and local governments. https://www.ada.gov/resources/2024-03-08-web-rule/
How is your institution defining, supporting, and evaluating the quality of its online courses? Are you seeing similar challenges, and what approaches have been effective in addressing them?
