Executive Policy 5.301 Executive Policy 5.301

Learning Management System (LMS) Use

Executive Policy Chapter 3, Academic Affairs
Executive Policy EP 5.301, Learning Management System (LMS) Use
Effective Date: March 25, 2026
Prior Dates Amended: N/A
Responsible Office: Office of the Vice President for Information Technology/CIO
Governing Board of Regents Policy RP 2.202 Duties of the President
Review Date: March 2029

1. The University of Hawaiʻi System shall establish guidelines for the use of the enterprise Learning Management System (LMS) and third-party educational technologies integrated within the enterprise LMS.


2. To strongly encourage the use of the enterprise LMS, as this consistency contributes materially to student success both by establishing a uniform tool for accessing course materials and by limiting the number of different technology platforms that any student must master.


3. Using the enterprise LMS or an alternative LMS that meets UH Information Security policies and complies with data privacy laws will significantly reduce the likelihood of a security breach. The enterprise LMS supports identity management to ensure that the student enrolled in the course is the person participating in the online course activities and assessments. The enterprise LMS serves as a single point of access for students to view course materials and grades.


4. The enterprise LMS is the best tool for academic units to provide evidence of RSI during an audit. Per US Department of Education regulations, online courses must provide evidence of regular and substantive interaction (RSI) between a student and instructor.


5. To ensure the electronic transmission of confidential and personally identifiable information (PII) in online courses is less vulnerable to cyberattacks, particularly from endpoint security, privacy, and process perspectives. The enterprise LMS has been vetted through the data governance process (DGP). Executive Policies 2.214 and 2.215 set forth data governance and security policies applicable to handling University data. Obligations to transmit University data to the other party or third parties will be included.


6. To establish definitions and guidelines for academic units that allow for the use of an alternative LMS or third-party tools.

1. IDAP is the UH Interactive Digital Access Program.


2. Learning Management System


1. A Learning Management System (LMS) is a software application or web-based technology used to plan, implement, and assess a specific learning process, with a primary function of facilitating and managing all aspects of an online or distance course. An LMS focuses on online learning delivery but also supports a range of uses, serving as a platform for online content in in-person and hybrid courses.


3. Regular and Substantive Interactions


1. Regular and Substantive Interactions (RSI) is a key requirement under the U.S. Department of Education’s definition of Distance Education. To comply with the requirement for RSI, the Distance Education course must include:


1. Substantive Interaction: The interaction must be meaningful and


2. directly related to the course content and provided by an instructor qualified in the subject matter.


3. Regular interaction: The interaction must be predictable and frequent, involving scheduled opportunities for instruction, feedback, or engagement.


4. Web Content Accessibility Guidelines (WCAG) are international standards from the W3C designed to make digital content accessible to people with disabilities. They provide actionable, testable criteria, legally required under the Americans with Disabilities (ADA) act, ensuring that websites are perceivable, operable, understandable, and robust.

1. All online and hybrid classes must be delivered via a learning management system (LMS) that meets the policies and laws specified here. While the use of an LMS in an in-person class is optional, any LMS deployed by an instructor must also meet these criteria:


1. UH Information Security policies:


1. Applicable data privacy laws include FERPA, GDPR, CCPA, COPPA, PIPEDA, ISO 27018, Cloud Security Alliance (CSA), and Security Trust and Assurance Registry (STAR).


2. All content must meet current WCAG accessibility guidelines


3. Any other relevant UH policies and guidelines.


2. A course is “delivered” in an LMS for purposes of this policy when, at a minimum, the following requirements are met:


1. The course syllabus must be posted in an accessible format that complies with applicable campus requirements.


1. Posting the syllabus in the LMS supports transparency and accountability for students in online courses.


2. The LMS gradebook and announcements functions must be used.


1. Regular updates serve as a consistent channel for disseminating schedule changes, clarifying assignments, and announcing upcoming events or deadlines.


2. The gradebook in the LMS centralizes and organizes all assessment data and provides students with a private, secure, and individualized view of their course progress.


3. All confidential and personally identifiable information (PII) about students must be stored in the LMS and may not be transmitted via email or any technology that does not meet UH cybersecurity policies and applicable data privacy laws.


4. All recordings of course sessions that contain personally identifiable information (PII) of enrolled students must be protected to comply with FERPA regulations. The recordings must be security stored in a UH-issued Dropbox account. If the recording is made available to students in the LMS, it must be linked to the course section in which the students identified in the recording are enrolled. Recordings containing PII must be deleted after the semester ends. Additionally, best practices on recordings are available on the UH Data Governance webpage.


3. Use of the university-supported (enterprise) LMS is strongly recommended. Although a college/academic unit may choose to allow use of an alternative LMS other than the enterprise LMS, the following points must be considered:


1. The alternative product is not under a UH enterprise license. This means that the instructor’s data and students’ FERPA-protected data are subject to the software’s online privacy policy and terms and conditions.


2. Most free or low-cost subscription-based software uses targeted advertising. UH Executive Policy 2.219 prohibits online vendors from using personal student data in targeted advertising. Advertising and social media cookies do not collect personal data; they track an individual’s movements across the Internet. The policy will allow the use of these cookies, provided that clear opt-out options are available, and the instructor notifies students at the beginning of the semester where to find the opt-out information.


3. Information Technology Services (ITS) Help Desk and ITS LMS Administrators do not support non-UH-supported LMS products, including Google Classroom. This includes LTI connections to third-party tools, including IDAP. Students enrolled will not be integrated with the Student Information System.


4. The following conditions must be met when an LMS other than the enterprise (non-supported) LMS is allowed by a college/academic unit:


1. The faculty member of record for each course using an LMS other than the enterprise LMS must obtain Data Governance Process (DGP) approval before collecting personally identifiable student data (education records subject to FERPA) in the non-supported LMS. Examples of student data may include names and email addresses submitted by the instructor, along with coursework, tests, quizzes, and grades.


2. An exception is being made for Google Classroom, which does not require a DGP because it is part of the University’s Google Core Apps. Refer to Google Classroom exception and DGP instructions.


3. The college/academic unit assumes the cost and liabilities associated with using a non-supported LMS. All procurement rules must be followed.


4. The college/academic unit is responsible for course enrollment and ensuring that its data complies with UH enrollment and grades guidelines.


5. The college/academic unit is responsible for integrating the LMS with the Student Information System (SIS) and other technologies as needed (including third-party e-learning tools) to ensure compliance with IPEDS, ADA, homeland security/visa status, and NC-SARA reporting requirements.


6. The college/academic unit is responsible for ensuring that access to content in the non-supported LMS complies with current WCAG accessibility guidelines.


7. The college/academic unit is responsible for training and support as well as ongoing maintenance and security vulnerability updates of the environment.


5. Many third-party education technology tools can be integrated into an LMS using the Learning Tools Interoperability (LTI) standards. The following conditions must be met when third-party education technologies are integrated into either the enterprise LMS or a non-supported LMS:


1. Follow the LTI Integration Process Decision Tree to determine the steps required to request the integration of an Instructional third-party online tools for possible LTI integration within an LMS.


2. For faculty integrating instructional online tools into the enterprise LMS that are not part of the IDAP initiative, must be reviewed through the Data Governance Process to ensure that the vendor’s terms and conditions for the instructional technology tool comply with FERPA and UH data privacy and protections policies and meet WCAG accessibility guidelines. Refer to the UH ITS Reviewed Third Party Tools list for instructional technology tools that have been reviewed and approved.


3. For tools that have been approved or conditionally approved on the UH ITS Reviewed Third Party Tools list, an LTI Integration Request Form must be submitted in accordance with the Integrating 3rd-Party Instructional Technology Tools Standard Operating Procedures.


4. The LTI integration supported by the UH LMS administration team shall only be incorporated into the UH enterprise LMS, not into non-supported LMS sites.


5. The LTI integration Request form is not required for faculty to submit digital course materials offered through the IDAP initiative.


6. Open Educational Resources (OER) materials may be integrated into the enterprise LMS by submitting the LTI Integration Request Form if the OER uses LTI standards.

Vice Presidents, Chancellors, Deans, and Directors are hereby directed with the authority to implement this Policy. The Vice President for Information Technology/Chief Information Officer is responsible for insuring and updating requirements, standards, and guidelines that support the Policy and facilitating regular communication with campuses, colleges, departments, and units to ensure consistent implementation of this Policy throughout the University system. For the individual or unit responsible for web content, help with the Policy is available on the Information Technology Accessibility website (www.hawaii.edu/access) or via the additional contact information below.

The EEO Officer and ADA Coordinator for each campus are responsible for ensuring compliance with state and federal regulations prohibiting discrimination on the basis of disability and requiring responsible accommodations. Questions or concerns regarding discrimination or reasonable accommodation complaints related to LMS access should be directed to the appropriate EEO Officer and/or ADA Coordinator. For advice on student auxiliary aids and services, direct inquiries to the student disability services office at each campus.

Office of the Vice President for Information Technology/Chief Information Officer
Telephone: (808) 956-3501
Email: gyoshimi@hawaii.edu
Website: https://www.hawaii.edu/its/

Subject Matter Expert:
Office of the Vice President for Academic Strategy
Telephone: (808) 956-6897
Email: ovpas@hawaii.edu

1. Data Governance Process (DGP)


2. Google Classroom exception and DGP instructions.


3. LTI Integration Process Decision Tree


4. UH ITS Reviewed Third-Party Tools list


5. LTI Integration Request Form

No Exhibits and Appendices found