2023-106 University of California
It Makes Limited Use of Online Program Management Firms but Should Provide Increased Oversight
Published: June 6, 2024Report Number: 2023-106
Audit Recommendations Disclosure
When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.
Recommendations to UC Office of the President
Recommendation 1
To promote practices that will mitigate the risks of using OPMs, the Office of the President should, with input from relevant stakeholders, such as extension unit deans and using the guidance provided by WASC, create guidance by June 2025 for UC’s use of OPMs. The guidance should define the OPMs to which it applies and, at a minimum, establish the following expectations:
- Campuses should ensure a minimum level of transparency about an OPM’s involvement in education programs, including requiring accurate public-facing website descriptions of the services an OPM provides and requiring the publication of the names and qualifications of OPM-paid instructors on public-facing websites, when applicable. This guidance should establish expectations for the minimum level of review that campuses should perform of websites and other marketing or recruiting materials for their programs that involve an OPM.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
On June 11, 2024, UC President Michael Drake sent a letter to the UC Chancellors “asking each Chancellor whose programs make use of OPMs to immediately take steps to correct any instances of misrepresentation or lack of transparency about how the program uses OPMs in all communications with existing and prospective students.” In that letter President Drake further states: “Our plan is to expeditiously create a process to develop formal guidance on UC’s use of OPMs within the time frame required by the audit. Relevant campus stakeholders will be consulted in the process.”
UCOP is in the process of establishing a systemwide OPM work group whose primary charge will be to draft system-wide guidelines/policy to address this and the other CSA recommendations directed to UCOP. The workgroup will include representatives of the Academic Senate, UC Extension, Graduate Deans, and other stakeholders.
We expect the workgroup to begin deliberations in the fall when the campuses are back in session.
Recommendation 2
To promote practices that will mitigate the risks of using OPMs, the Office of the President should, with input from relevant stakeholders, such as extension unit deans and using the guidance provided by WASC, create guidance by June 2025 for UC’s use of OPMs. The guidance should define the OPMs to which it applies and, at a minimum, establish the following expectations:
- Campuses should provide adequate oversight of OPMs that provide instruction on behalf of UC and the steps the campuses should take to review, approve, and evaluate OPM-created courses and OPM-provided instructors. The guidance should specifically address collecting student evaluations of OPM courses and should establish expectations for campuses’ reviews of those evaluations following each academic term.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
UCOP is in the process of establishing a systemwide OPM work group whose primary charge will be to draft system-wide guidelines/policy to address this and the other CSA recommendations directed to UCOP. The workgroup will include representatives of the Academic Senate, UC Extension, Graduate Deans, and other stakeholders.
We expect the workgroup to begin deliberations in the fall when the campuses are back in session.
Recommendation 3
To better protect prospective students from recruiting practices that are not in their best interests, the Office of the President should expand its existing guidance on incentive compensation by June 2025 to address graduate and continuing education students. The expanded guidance should describe that UC discourages tuition revenue sharing or bonus payments to entities that recruit graduate or continuing education students, as it does for undergraduate students. Further, the expanded guidance should describe the safeguards that campuses should adopt to mitigate the risks posed to students and to better ensure UC’s compliance with federal law.
Status
Not fully implemented
Date of implementation
November 2024
Evaluator assessment status
pending
60-Day Agency Response
UCOP is in the process of establishing an OPM work group whose primary charge will be to draft system-wide guidelines/policy to address this recommendation and the other CSA recommendations, including expanding existing guidance on incentive compensation to graduate and continuing education students. The workgroup will include representatives of the Academic Senate, UC Extension, Graduate Deans, and other stakeholders.
We expect the workgroup to begin deliberations in the fall when the campuses are back in session.
Recommendations to UC Berkeley
Recommendation 4
To provide transparency to prospective students regarding course instruction, by June 2025, UC Berkeley should engage with relevant stakeholders regarding creating or amending its policies or processes to require that course descriptions and program websites include the following:
- Disclosure of the partnership between an OPM and the campus.
- A description of the OPM’s roles, particularly when the OPM provides instruction.
- Identification of OPM instructors as well as their training and experience.
- Disclosure of the amounts of any nonrefundable deposits or fees.
Status
Not fully implemented
Date of implementation
12/15/2024
Evaluator assessment status
pending
60-Day Agency Response
The Berkeley campus is in the process of updating its local policy on engagement with third-party providers to include the requirements mentioned in audit recommendations 4 and 5. We expect an updated policy to be approved by December 15, 2024.
Recommendation 5
To ensure that it does not provide misleading information on their websites, by June 2025, UC Berkeley should engage with relevant stakeholders regarding creating and implementing a policy to review, on no less than an annual basis, the program websites associated with courses that OPMs support to ensure that the information provided is current and accurate. UC Berkeley should formally document these reviews and track any needed or subsequent changes.
Status
Not fully implemented
Date of implementation
2/01/2025
Evaluator assessment status
pending
60-Day Agency Response
The Berkeley campus is in the process of updating its local policy on engagement with third-party providers to include the requirements mentioned in audit recommendations 4 and 5. We expect an updated policy to be approved by December 15, 2024.
In addition, the campus NAV-B unit has been identified as the unit to review the program websites. We expect the first cycle of review of campus websites to begin by February 1, 2025 and this process will include documentation of completed reviews as well as tracking of items identified requiring correction or change.
Recommendation 6
To ensure that Berkeley Extension receives the full amounts owed to the campus according to the terms of its OPM contracts, by June 2025, Berkeley Extension should establish a process to verify that the revenue amounts received from each OPM are accurate.
Status
Not fully implemented
Date of implementation
03/01/2025
Evaluator assessment status
pending
60-Day Agency Response
The campus NAV-B unit is currently working with University Extension to evaluate their current process, and to provide guidance on updating said process. We expect that UNEX will update its process, including formal documentation, by March 1, 2025.
Recommendations to UC Davis
Recommendation 7
To provide transparency to prospective students regarding course instruction, by June 2025, UC Davis should engage with relevant stakeholders regarding creating or amending its policies or processes to require that course descriptions and program websites include the following:
- Disclosure of the partnership between an OPM and the campus.
- A description of the OPM’s roles, particularly when the OPM provides instruction.
- Identification of OPM instructors as well as their training and experience.
- Disclosure of the amounts of any nonrefundable deposits or fees.
Status
Not fully implemented
Date of implementation
06/06/2025
Evaluator assessment status
pending
60-Day Agency Response
As of August 2024, UC Davis has taken the following action in response to the CSA’s recommendations:
- Convened a working group of stakeholders tasked with drafting policy language
- Established lines of coordination with UCOP to ensure that changes to local policy reflect changes to systemwide policy
- Held preliminary discussions with the UC Davis Academic Senate to understand its expectations and set a timeline for its participation in finalizing new policy
- Identified a timeline for action:
- The working group will draft suggested policy language by 10/31/24
- Suggested policy language will be submitted to the Chancellor and Provost, who will provide comment by 11/30/24
- Suggested policy language reflecting leadership’s comments will be submitted to the Academic senate by 12/31/24
- The Academic senate will provide comments and/or revisions to the policy language by 3/31/25
- The working group will incorporate comments and/or revisions provided by the Academic Senate and submit final policy language to the Chancellor and Provost for approval by 4/30/25
- The Chancellor and Provost will provide any additional comments to the working group throughout the month of May 2025, and final approval of policy language by 5/31/25
UC Davis will publish new and/or revised policy language by 6/6/25
Recommendation 8
To ensure that it does not provide misleading information on their websites, by June 2025, UC Davis should engage with relevant stakeholders regarding creating and implementing a policy to review, on no less than an annual basis, the program websites associated with courses that OPMs support to ensure that the information provided is current and accurate. UC Davis should formally document these reviews and track any needed or subsequent changes.
Status
Not fully implemented
Date of implementation
06/06/2025
Evaluator assessment status
pending
60-Day Agency Response
As of August 2024, UC Davis has taken the following action in response to the CSA’s recommendations:
- Convened a working group of stakeholders tasked with drafting policy language
- Established lines of coordination with UCOP to ensure that changes to local policy reflect changes to systemwide policy
- Held preliminary discussions with the UC Davis Academic Senate to understand its expectations and set a timeline for its participation in finalizing new policy
- Identified a timeline for action:
- The working group will draft suggested policy language by 10/31/24
- Suggested policy language will be submitted to the Chancellor and Provost, who will provide comment by 11/30/24
- Suggested policy language reflecting leadership’s comments will be submitted to the Academic senate by 12/31/24
- The Academic senate will provide comments and/or revisions to the policy language by 3/31/25
- The working group will incorporate comments and/or revisions provided by the Academic Senate and submit final policy language to the Chancellor and Provost for approval by 4/30/25
- The Chancellor and Provost will provide any additional comments to the working group throughout the month of May 2025, and final approval of policy language by 5/31/25
UC Davis will publish new and/or revised policy language by 6/6/25
Recommendations to UC Los Angeles
Recommendation 9
To provide transparency to prospective students regarding course instruction, by June 2025, UCLA should engage with relevant stakeholders regarding creating or amending its policies or processes to require that course descriptions and program websites include the following:
- Disclosure of the partnership between an OPM and the campus.
- A description of the OPM’s roles, particularly when the OPM provides instruction.
- Identification of OPM instructors as well as their training and experience.
- Disclosure of the amounts of any nonrefundable deposits or fees.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
UCLA has convened a working group with campus stakeholders in response to the California State Auditor’s report on online program management firms (OPMs). At the initial meeting, stakeholders discussed the recommendation details outlined in the report and developed a working plan to implement recommendations by June 2025.
UCLA’s OPM working group discussed the development of campuswide policies and revisions to local processes regarding the disclosures of OPM partnerships, OPM roles, instructor training and experience, and any nonrefundable deposits or fees. We have since reviewed an initial framework to consider in the development of a campuswide policy.
As the CSA report also includes recommendations to the UC Office of the President for the creation of systemwide guidelines by June 2025, UCLA is participating in a systemwide workgroup to evaluate UC guidelines for implementation and ensure draft UCLA policies are aligned with final systemwide guidance.
Timetable:
- September 2024 – Initial draft of campuswide policy for UCLA policy manager review
- December 2024 – Revised draft of campuswide policy for key campus stakeholders’ review
- June 2025 – Implement campuswide policy
Recommendation 10
To ensure that it does not provide misleading information on their websites, by June 2025, UCLA should engage with relevant stakeholders regarding creating and implementing a policy to review, on no less than an annual basis, the program websites associated with courses that OPMs support to ensure that the information provided is current and accurate. UCLA should formally document these reviews and track any needed or subsequent changes.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
UCLA has convened a working group with campus stakeholders in response to the California State Auditor’s report on online program management firms (OPMs). At the initial meeting, stakeholders discussed the recommendation details outlined in the report and developed a working plan to implement recommendations by June 2025.
UCLA’s OPM working group discussed the development of campuswide policies and revisions to local processes regarding the disclosures of OPM partnerships, OPM roles, instructor training and experience, and any nonrefundable deposits or fees. We have since reviewed an initial framework to consider in the development of a campuswide policy.
As the CSA report also includes recommendations to the UC Office of the President for the creation of systemwide guidelines by June 2025, UCLA is participating in a systemwide workgroup to evaluate UC guidelines for implementation and ensure draft UCLA policies are aligned with final systemwide guidance.
Timetable:
- June 2025 – Implement campuswide policy
- September 2024 – Initial draft of campuswide policy for UCLA policy manager review
- December 2024 – Revised draft of campuswide policy for key campus stakeholders’ review
Recommendation 11
To better monitor how well the OPMs are serving students, by June 2025, UCLA Extension should establish and implement a policy to review and assess the results of OPM-administered student course evaluations after each academic term.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
UCLA has convened a working group with campus stakeholders in response to the California State Auditor’s report on online program management firms (OPMs). At the initial meeting, stakeholders discussed the recommendation details outlined in the report and developed a working plan to implement recommendations by June 2025.
UCLA’s OPM working group discussed the development of a policy to review and assess the results of OPM-administered student course evaluations after each academic term. We have since reviewed an initial framework to consider in the development of a policy to satisfy this recommendation.
As the CSA report also includes recommendations to the UC Office of the President for the creation of systemwide guidelines by June 2025, UCLA is participating in a systemwide workgroup to evaluate UC guidelines for implementation and ensure draft UCLA policies are aligned with final systemwide guidance.
Timetable:
- September 2024 – Initial draft of policy for UCLA policy manager review
- December 2024 – Revised draft of policy for key campus stakeholders’ review
- June 2025 – Implement and enforce policy
Recommendation to UC San Diego
Recommendation 12
To provide transparency to prospective students regarding course instruction, by June 2025, UC San Diego should engage with relevant stakeholders regarding creating or amending its policies or processes to require that course descriptions and program websites include the following:
- Disclosure of the partnership between an OPM and the campus.
- A description of the OPM’s roles, particularly when the OPM provides instruction.
- Identification of OPM instructors as well as their training and experience.
- Disclosure of the amounts of any nonrefundable deposits or fees.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
This recommendation was still in process as of the date of this update. Both the general UCSD Campus and UCSD Extended Studies have initiated steps to ensure that OPM course websites are updated to include the information listed in this recommendation. Over the next couple months, UCSD will engage with the relevant stakeholders on a policy/process for requiring that course descriptions and websites include this information going forward. We expect that this recommendation will be completed no later than June 2025.
Recommendation 13
To ensure that it does not provide misleading information on their websites, by June 2025, UC San Diego should engage with relevant stakeholders regarding creating and implementing a policy to review, on no less than an annual basis, the program websites associated with courses that OPMs support to ensure that the information provided is current and accurate. UC San Diego should formally document these reviews and track any needed or subsequent changes.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
This recommendation was still in process as of the date of this update. Over the next couple months, UCSD will engage with relevant stakeholders regarding implementation of a policy to annually review program websites associated with courses that OPMs support to ensure that the information provided is current and accurate, including a requirement that these reviews be formally documented. We expect that this recommendation will be completed no later than June 2025.
Recommendation 14
To prevent prospective students from being misled about the value of OPM-provided courses, by June 2025, UC San Diego should develop fact sheets that list key information for each course or program, such as whether the course provides a benefit for admission to another campus degree program.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
This recommendation was still in process as of the date of this update. UCSD has initiated a revision of its fact sheets and FAQs to ensure that students receive consistent and accurate information across the organization. This effort aims to enhance clarity and reliability for all stakeholders. We expect that these fact sheets will be finalized no later than June 2025.
Recommendation 15
To prevent prospective students from being misled about the value of OPM-provided courses, by June 2025, UC San Diego should request that its Academic Senate assess whether the campus should continue to use the term MicroMasters.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
This recommendation was still in process as of the date of this update. By June 2025, UCSD will request that its Academic Senate assess whether the campus should continue to use the term MicroMasters.
Recommendation 16
To comply with Academic Senate rules and its own policies regarding course and instructor approvals, by June 2025, San Diego Extension should establish a process to document all OPM course and instructor approvals.
Status
Not fully implemented
Date of implementation
June 2025
Evaluator assessment status
pending
60-Day Agency Response
This recommendation was still in process as of the date of this update. UCSD Extended Studies is actively reviewing and updating its course and instructor approval processes, with the objective of strengthening controls and better ensuring that instructor approvals are completed in a timely manner, prior to the commencement of courses. We expect to have these processes updated no later than June 2025.
Recommendation to UC Santa Barbara
Recommendation 17
To provide transparency to prospective students regarding course instruction, by June 2025, UC Santa Barbara should engage with relevant stakeholders regarding creating or amending its policies or processes to require that course descriptions and program websites include the following:
- Disclosure of the partnership between an OPM and the campus.
- A description of the OPM’s roles, particularly when the OPM provides instruction.
- Identification of OPM instructors as well as their training and experience.
- Disclosure of the amounts of any nonrefundable deposits or fees.
Status
Not fully implemented
Date of implementation
06/06/2025
Status
pending
60-Day Agency Response
To date we have reviewed the partners’ websites to make sure information was presented as recommended, including:
- Full disclosure of costs, with no hidden fees
- Instructor information & contact
- Full disclosure of the partnership, adoption of a standard partnership logo, and statement on the partner’s side main page.
We are establishing formal requirements in a set of guidelines for future partnerships.
Recommendation 18
To ensure that it does not provide misleading information on their websites, by June 2025, UC Santa Barbara should engage with relevant stakeholders regarding creating and implementing a policy to review, on no less than an annual basis, the program websites associated with courses that OPMs support to ensure that the information provided is current and accurate. UC Santa Barbara should formally document these reviews and track any needed or subsequent changes.
Status
Not fully implemented
Date of implementation
12/06/2024
Status
pending
60-Day Agency Response
We are documenting a workflow for performing quarterly reviews whereby the Program Managers will conduct the quarterly reviews. Specific details should be available in the next month.
Recommendation 19
To better monitor how well the OPMs are serving students, by June 2025, Santa Barbara Extension should establish and implement a policy to review and assess the results of OPM-administered student course evaluations after each academic term.
Status
Not fully implemented
Date of implementation
09/01/2024
Status
pending
60-Day Agency Response
UCSB has met with all our current OPM representatives to discuss sharing student evaluation results. Evaluation sharing is now contractually required in an amendment and will be included in a one-year provisional contract approval. Upon contract renewal, evaluations and new instructor qualifications will be reviewed quarterly.
Contract language:
A. Article 16. “Audit Compliance,” is hereby added as follows:
Pursuant to findings in the 2024 Auditor of the State of California Report #2023-106, Company agrees to allow University to review and assess the results of the student course evaluations after each academic term. The University also reserves the right to review Company’s course instructor’s qualifications before approving a course.
Recommendation 20
To ensure that the OPM instructors teaching students on its behalf are sufficiently qualified, by June 2025, Santa Barbara Extension should incorporate a review of the instructors’ qualifications into its OPM course approval process.
Status
Not fully implemented
Date of implementation
09/01/2024
Evaluator assessment status
pending
60-Day Agency Response
We are documenting a workflow for Program Managers to perform quarterly reviews. Specific details should be available in the next month. As a part of the contractually required amendment noted in Recommendation 19, new instructor qualifications will also be reviewed quarterly.