[State_authorization_update] June Updates

Fri Jul 1 16:56:03 EDT 2016

Good afternoon everyone,

Here is a list of the latest updates for state authorization. There is some really great and important news included below. Please contact me by email or phone if you have any questions concerning these matters.

SARA Updates:
The following states and district are now members of SARA. Please note some states have an effective date which allows the state time to finalize any regulatory process and finalize the institution approval procedures.

*        Delaware -    Effective date of Sept. 1, 2016

*        District of Columbia - Effective date July 1, 2016

*        North Carolina - Effective date June 13, 2016

*        South Carolina - Effective date June 10, 2016
Please read the following link gain detailed information on field experience limitations through reciprocity coverage: http://nc-sara.org/content/sara-and-institutions
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New Proposed Federal Regulations:

The state authorization for distance education regulation could come out fairly soon. These regulation changes could include:

*        Demonstrating compliance for Financial Aid purposes

*        Reciprocity support

*        Military Exemptions

*        Disallowance of state exemptions

*        Increased notification requirements for ALL licensure programs on campus (face-to-face and distance education)

There are a few steps universities could be taking in preparation for the release of the proposed rules.

Step 1: Assess Your Institution's Vulnerabilities
Remember that the Department will be checking to see if your institution has the approval of states in which students receiving federal financial aid are located. Some items to check:

  *   Are there states in which you are enrolling students and you are not approved by that state? If you must seek approval outside of SARA, remember that the state regulators will feel no obligation to fast track you because of the new federal regulation. Remember that authorization is not just about distance education, it is about all activities in another state.
  *   Do you have adequate processes and policies for checking student location? You need to know where your students are located to be in compliance in a state. Based on previous guidance when the federal regulation was to be enforced, you need to regularly update that data every time you certify students for financial aid eligibility. Will you be able to meet that requirement now or in the next few years? Again, we don't know when they will begin enforcing these rules.
  *   If you have programs that lead to licensure (nursing, teacher education, psychology, etc.), are you able to positively say if the program meets the academic requirements for sitting for licensure in those states?
  *   If you are offering 50% or more of a program face-to-face in another state, then under current regulations you already are supposed to have the approval (if necessary) of that state.
  *   If you do not have approvals or do not meet licensure requirements in some states, are you prepared to deny admissions from that state? Do you have the processes to do so?
  *   Do you have the institutional support to get all parts of the institution to work together? Obtaining authorization is an institution-wide endeavor.

Those are some examples. What states have you worried about where you might not be fully following the rules? What policies, processes, or other support do you need to comply? Of course, we do not know exactly what requirements will be included in the regulations. You will need to make your best guess based upon what we currently know.

Step 2:  Inform Your Leadership
Let them know:

  *   What are the consequences of being out of compliance? The Department of Education will check for compliance during normal financial aid reviews (sometimes called audits) or if they are given a reason to request it.
  *   What can we do in the short term? I suggest you be prepared to comment.

Step 3:  Prepare to Comment
The time to provide comments to the Department of Education might be as short as 30 days. Questions to ask:

  *   Is your institution willing to submit an official comment?
  *   What might you say in that comment?
  *   What impact would you like to let share with the Department?
  *   Do you have Congressional influence that you can leverage?

WCET will provide some suggested language when the final regulation is released. The institution may make a formal comment or individuals may comment as long as they are clear that they are not commenting on behalf of the institution. Remember that volume counts during commenting periods.

Finally
Universities will need to decide how to navigate the waters locally. It is good to be prepared to eliminate surprises.

Russell Poulin
Director, Policy & Analysis
WCET - The WICHE Cooperative for Educational Technologies
303 - 541 - 0305
rpoulin at wiche.edu    @russpoulin

Additional resource: from a recent edition of Inside Higher Ed.  This article refers to the news that the Department of Education submitted to the Office of Management and Budget (OMB) new proposed regulations for the State Authorization of distance education.
https://www.insidehighered.com/news/2016/06/06/education-department-make-final-push-state-authorization-rule?utm_source=Inside+Higher+Ed&utm_campaign=1a507046c7-DNU20160606&utm_medium=email&utm_term=0_1fcbc04421-1a507046c7-198668573#.V1Vaofgbpc8.mailto

Enjoy your weekend!
Kia

[OHIO University]
Office of Instructional Innovation
Kia D. Stone, Coordinator of Compliance & Quality Assurance
115 Haning Hall  | Ohio University |  Athens OH 45701-2979
T: 740.593.2558 | stonek1 at ohio.edu<mailto:stonek1 at ohio.edu>
https://www.ohio.edu/instructional-innovation/state-authorization/index.html

**If you would like to be included on updates concerning State Authorizations, please add your email to the following link http://listserv.ohio.edu/mailman/listinfo/state_authorization_update.

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