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State Authorization. Monday, April 11, 2011 Tuesday, April 12, 2011. The regulation Section 600.9.
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State Authorization Monday, April 11, 2011 Tuesday, April 12, 2011
The regulation Section 600.9 • If an institution is offering postsecondary education through distance or correspondence education to students in a State in which it is not physically located or in which it is otherwise subject to State jurisdiction as determined by the State, the institution must meet any State requirements for it to be legally offering postsecondary distance or correspondence education in that State. An institution must be able to document to the Secretary the State’s approval upon request. • http://tinyurl.com/47vxesx
Not new federal laws but enforcement of existing state laws • To comply, institutions must • Get authorized in any state where your institution has distance students—whatever that process • Provide students from other states with contact information for the complaint process in their state • Enforcement begins July 1, 2011
Some clarifications: • Not about residential students, so if they live in Washington while attending your school, no authorization is needed • May involve other requirements and costs, such as a business license for that state • Infractions will be discovered through audit process • USDOE will accept a “good-faith” effort for the 2011-2012 year • WCET working on list of complaint contacts by state
Penalty for Non-compliance • Return of Title IV federal financial aid funds that were disbursed to students from the state for which your college is not authorized • Accreditation may require you to teach- out students from another state who are currently in programs at your college
Why now? • USDOE believes this will protect federal financial aid dollars • USDOE believes this will protect students • USDOE so far does not believe this will be a burden to colleges (plus, they are just enforcing existing state laws)
Sir John Daniel said about his attempt to create a US Open University: • “When I brought the OU to America I thought I would be dealing with one country. I was mistaken.” • http://www.insidehighered.com/layout/set/popup/views/2011/02/18/goldstein
….and this elephant isn’t even standing still….. • States are changing and clarifying their rules • Efforts to extend timeline • Efforts to establish reciprocal agreements • Efforts to establish common requirements
College Process Ideas • To comply each college has to make decisions on how to proceed • Short-term: deadline July 1, 2011 • Long-term: Authorization and fees are an annual process
Establish your committee and project manager • People to include: • Elearning • Institutional research • Public information/marketing • Registration • Financial aid • Others?
Gather information • How many students in how many states? • Details of your presence in each state? • Costs in money and time to comply with each state? • Use links in Starter List: (It’s already out of date)http://stateregulations.wikispaces.com/Research
Some questions to ask about “presence” (Remember everything varies by state) • Does your college have a site in that state? • Does your college market to that state? • Does your college hire faculty who live in that state? • Do your students do internships in that state? • Do your students work toward professional licenses? (i.e., nursing)
Tips from those who have gone before…. • Your communication with states should be positive and signal that you want to be in compliance. The state officers are likely underfunded and overwhelmed, too. • You can ask for a waiver if you have to teach-out students who move to another state mid-program. • Keep detailed records
SBCTC eLearning: • Has joined WCET State Authorization Network-- • access to information and reform efforts • Will attend or report to councils and commissions on this issue • Will post information on this wiki: (Thanks, Shoreline!) • http://stateregulations.wikispaces.com/
SBCTC eLearning • Will collect questions for AAG • Will attempt to get authorization for whole system in some states—starting with the closest (and maybe easiest)—Will need feedback from colleges on where to start and possibly other details: • Idaho • Montana • California • Oregon • (The right ones to start with?)
What will help… • Provide a single contact at each college—the project manager? • Lead for SBCTC: • Connie Broughton, cbroughton@sbctc.edu
What else will help… • Post whatever you learn, decide or create on wiki: • http://stateregulations.wikispaces.com/
April Meetings • Two Elluminate sessions (same agenda) • Monday, April 11 at 11:00 am • Tuesday, April 12 at 3:00 pm • To attend: https://sas.elluminate.com/m.jnlp?sid=2008170&password=M.6572CB4EFB13FD9E7F09659413DBD6 Recordings will be on the wiki
Questions? • Connie Broughton cbroughton@sbctc.edu