Two of the common themes in the commentary that have been provided by both CANeLearn and the researchers at the State of the Nation: K-12 e-Learning in Canada has been the success or failure of the e-learning mandate will be due to exactly how the Government of Ontario decides to implement it and the Government has not released enough details to seriously analyze their proposal.  To date, the only firm details that have been released about the Government’s intentions come from the 15 March 2019, when they announced the Education that Works for You – Modernizing Classrooms proposed policy calling for:


The government is committed to modernizing education and supporting students and families in innovative ways that enhance their success. A link to e-learning courses can be found here:

Starting in 2020-21, the government will centralize the delivery of all e-learning courses to allow students greater access to programming and educational opportunities, no matter where they live in Ontario.

Secondary students will take a minimum of four e-learning credits out of the 30 credits needed to fulfill the requirements for achieving an Ontario Secondary School Diploma. That is equivalent to one credit per year, with exemptions for some students on an individualized basis. These changes will be phased in, starting in 2020-21.

With these additional modernizations, the secondary program enhancement grant will no longer be required.

This past week there did appear to be two developments.  First, in response to questioning in the legislature, the Government began to point to various states that have online learning graduation mandates, specifically Alabama, Arkansas, Florida, and Michigan.  Second, this tweet was posted by Queen’s Park Reporter, Kristin Rushowy




We point to these two, seemingly minor, occurrences because they do represent some of the only details that are currently available related to the Government’s thinking around the implementation of their 15 March announcement. So let’s examine these details…

Michigan, which was one of the four states referenced, passed its online learning requirement in 2006 and it first applied to the Class of 2011.  The legislation reads:

380.1278a Requirements for high school diploma.

Sec. 1278a.

(1) Except as otherwise provided in this section or section 1278b, beginning with pupils entering grade 8 in 2006, the board of a school district or board of directors of a public school academy shall not award a high school diploma to a pupil unless the pupil meets all of the following:

(b) Meets the online course or learning experience requirement of this subsection. A school district or public school academy shall provide the basic level of technology and internet access required by the state board to complete the online course or learning experience. For a pupil to meet this requirement, the pupil shall meet either of the following, as determined by the school district or public school academy:

(i) Has successfully completed at least 1 course or learning experience that is presented online, as defined by the department.

(ii) The pupil’s school district or public school academy has integrated an online experience throughout the high school curriculum by ensuring that each teacher of each course that provides the required credits of the Michigan merit curriculum has integrated an online experience into the course. (Michigan Department of Education, 2006, ¶ 1, 8-10)

This language has been operationalized so that the graduation requirement can be met in one of three ways:

  • complete at least one online course;
  • complete an online learning learning experience that is defined as 20 hours of online learning in a single course; or
  • complete technology-infused lessons incorporated into each of the required credit courses of the Michigan Merit Curriculum (Freidhoff, 2019)

So students in Michigan to meet their “online learning graduation requirement” can take an online course, take a classroom-based course that has a four-week unit in it that is delivered online, or they can simply take all of their other required courses and the school can simply ensure that at least one lesson in each of these courses is technology-infused.  It is worth noting that the majority of schools have decided to focus their implementation on the third option.

Alabama was the second state mentioned to implement an online learning graduation requirement in 2008, which came into effect for the Class of 2013.  This requirement followed the pattern set by Michigan in that it required students “to complete one on­line/technology  enhanced course or experience prior to graduation” (Alabama State Board of Education, 2008, p. 19).  The Alabama requirement also provided “exceptions through Individualized Education Plans” (p. 19) – in other words students who had an Individualized Education Plan, which applies to all special education students, could be exempt from the online learning requirement.

The third state referenced to implement their online learning graduation requirement was Florida, which passed the legislation in 2011 and came into effect for the Class of 2015.  The Florida requirement was among the most specific and stringent.  It required that students complete

at least one course within the 24 credits required in this subsection must be completed through online learning. However, an online course taken during grades 6 through 8 fulfills this requirement. This requirement shall be met through an online course offered by the Florida Virtual School, an online course offered by the high school, or an online dual enrollment course offered pursuant to a district interinstitutional articulation agreement pursuant to s. 1007.235. A student who is enrolled in a full-time or part-time virtual instruction program under s. 1002.45 meets this requirement.

The Florida graduation requirement is a full online course, with no exceptions.

Finally, the fourth state referenced by the Government to require online learning was Arkansas.  Arkansas introduced its mandate in 2013, and it first applied to the Class of 2018.  Students “shall be required to take at least one (1) digital learning course for credit to graduate” (Arkansas Department of Education, 2013, p. 4).  Interestingly, for the purpose of this requirement a digital learning environment was defined as:

(1) Access to quality digital learning content and online blended learning courses;

(2) Tailored digital content designed to meet the needs of each student;

(3) Digital learning content that meets or exceeds the curriculum standards and requirements adopted by the State Board of Education that is capable of being assessed and measured through standardized tests or local assessments; and

(4) Infrastructure that is sufficient to handle and facilitate a quality digital learning environment. (p. 2)

Additionally, digital learner providers must:

(4)(A) Utilizes highly qualified teachers to deliver digital learning courses to public school students.

(B) A highly qualified teacher that delivers digital learning courses under this subchapter is not required to be licensed as a teacher or administrator by the state board. (p. 3)

Finally, all digital learning courses must:

(3) Be made available in a blended learning, online-based, or other technology-based format tailored to meet the needs of each participating student. (p. 3)

Taken together, Arkansas requires that students complete one course that uses digital content, is offered in an online, blended, or other technology-based format, and is delivered by a certified teacher (although that teacher can live outside of Arkansas).

There are two other states that have some form of online learning graduation requirement (i.e., New Mexico and Virginia), as well as a number of school districts (Kennedy, 2019).  However, based on the ones specifically cited by the Government of Ontario this past week, their thinking around an e-learning mandate is informed by three jurisdictions where online learning is defined as an online course, an online unit, or an online lesson across multiple courses.  Their thinking around e-learning is also defined, at least in one instance, by a jurisdiction that allows an exemption for special needs students – which is something the Government seems to have suggested themselves.  In fact, in only one instance is their understanding of mandatory e-learning informed by an example where it is a complete online course with no exceptions.

Like so many aspects around the e-learning portion of the Education that Works for You – Modernizing Classrooms proposed policy, we continue to be left with speculation as to exactly how the Government of Ontario intends to implement these changes.



Alabama State Board of Education. (2008). Alabama Administrative Code (AAC) Rule 290-3-1-.02(12) for Online Courses. Montgomery, AL: Author. Retrieved from

Arkansas Department of Education. (2013). State of Arkansas House Bill Act 1280. Little Rock, AR: Author. Retrieved from

Florida Senate. (2011). CS/CS/HB 7197: Digital learning. Tallahassee, FL: Author. Retrieved from

Freidhoff, J. (2019, August).  Mandatory elearning: Lessons from Michigan. A keynote presentation to the Canadian e-Learning Network Leadership Summit, Toronto, ON. Retrieved from 

Kennedy, K. (2018, September 25). Online learning graduation requirements. Durango, CO: Digital Learning Collaborative. Retrieved from

Michigan Department of Education. (2006). 380. 1278a: Requirements for high school diploma. Lansing, MI: Author. Retrieved from

New Details About Ontario’s E-Learning Mandate

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