Last year, the Department of Education opened a veritable Pandora’s Box when it released new program integrity regulations as part of the reauthorization of Title IV in the Higher Education Act. These new DOE regulations used the little-known state authorization process as an enforcement tool. On July 12th 2011 a US District Court judge voided these regulations as a result of a lawsuit brought forth by a consortium of for-profit institutions. This decision is under appeal.
A number of representatives at higher education institutions breathed a sigh of relief, thinking they were off the hook in meeting these often draconian authorization requirements. After all, the regulations differ from state to state, can be expensive, and in most cases are a bureaucratic morass.
Unfortunately, they’re not off the hook.
This ruling on the federal regulations has no impact on the distance learning authorization regulations already in place in most states, nor does it change the expectation from the authorizing agencies in each state that individual institutions will begin to comply with these regulations.
Russ Poulin and the other folks at WCET have been at the forefront of this issue since it raised its thorny head back in 2010, and the WCET blog is the first place I go for updates on the state authorization issue and contains a pretty authoritative list of resources. Last month, WCET offered a helpful post to assist institutions in beginning to comply with these regulations. Read the full post. However, here is a bulleted list of WCET’s 10 Steps To Take to Begin the State Authorization Process:
- Select the right person to lead
- Review your enrollment history – do you know where your students are?
- Develop relationships across your institution
- Engage and inform institutional leaders
- Research state agency regulations
- Develop a relationship with regulators
- Determine where you will apply
- Determine post-approval steps and timelines
- Document what you do
I have created a website on State Authorization for colleges to use to share information and track their progress on this issue (login required).