State Authorization Updates on Regulations, Reciprocity, and Complaint Notifications Council of College and Military Educators – February 2016

wcet.wiche.edu Presenting 2 Russ Poulin Director, Policy & Analysis Cheryl Dowd Director, WCET State Authorization Network

wcet.wiche.edu WCET is the leader in the practice, policy, & advocacy of technology-enhanced learning in higher education.

wcet.wiche.edu WCET/ State Authorization Network Providing research, training, and collaboration to efficiently manage regulatory compliance of interstate activities in higher education.

wcet.wiche.edu Agenda  Basics of State Authorization  Federal Regulations  State Authorization Reciprocity Agreement (SARA)  State Trends & Updates  Military Students’ Common Concerns  Answering Your Questions

wcet.wiche.edu Basics of State Authorization State authorization… is something you should check if you are crossing a state line to perform ANY activity.

wcet.wiche.edu Basics of State Authorization There are two types of state authorization… Institutional   Licensure Programs

wcet.wiche.edu Basics of State Authorization State authorization… has consequences for non-compliance.

wcet.wiche.edu The “On Ground” Regulation Chapter 34, §600.9(a) & (b) In your state, know the state agency that… Approves institution. Hears complaints. Federal Regulations Chapter 34, §600.9(a) & (b)

wcet.wiche.edu The “Distance Ed” Regulation Chapter 34, §600.9(c) Still on “pause”… Federal Regulations Chapter 34, §600.9(c)

wcet.wiche.edu The “Distance Ed” Regulation Chapter 34, §600.9(c) Still on “pause”… …probably will not be reissued. Federal Regulations Chapter 34, §600.9(c)

wcet.wiche.edu The “Distance Ed” Regulation Chapter 34, §600.9(c) Still on “pause”… …probably will not be reissued. …HEA reauthorization increasingly unlikely. Federal Regulations Chapter 34, §600.9(c)

wcet.wiche.edu The Department of Defense is checking for state authorization for military students receiving Tuition Assistance. Are you finding this to be true? Federal Regulations

wcet.wiche.edu An interstate agreement. Voluntary for states and institutions to join. Covers institutional authorization for many activities in other states. State Authorization Reciprocity Agreement (SARA)

wcet.wiche.edu State Authorization Reciprocity Agreement (SARA)

wcet.wiche.edu SARA does not cover: Physical locations. Additional requirements for licensure programs. Field experiences with more than 10 students/program at a site. State Authorization Reciprocity Agreement (SARA)

wcet.wiche.edu 17 State Trends and Updates Some states recently revised regulations in anticipation of or in conjunction with becoming a SARA state. Changes include: Regulated activities in the state. Fees required for compliance. Application process.

wcet.wiche.edu 18 State Trends and Updates North Carolina The “Teach Out” options for field experiences no longer exists. Exceptions: 1.The student is in the military and transferred to North Carolina during their program of studies, or 2.The student moves to North Carolina during their program of studies. Contact Terrence Scarborough for more information about authorization in North

wcet.wiche.edu Military Students – Common Concerns Activity vs. Residency The residency of the student is irrelevant Location of activity determines the regulating state Must be prepared for students who get transferred Military Instillations Most states regulate activity on the instillation the same as anywhere else in the state. (check state regulations for the exceptions!)

wcet.wiche.edu 20 Military Students – Common Concerns Relocation Temporary Duty: States typically looking to where student is primarily located. Transfers: Many states offer waivers. Talk to the regulator.

wcet.wiche.edu 21 Military Students – Common Concerns Complaints States: Not SARA: state agency in student’s state. SARA: SARA agency in institution’s state. Department of Education: Notify “current and prospective” students where to complain to states and accrediting agencies. Creating new process for financial aid students.

wcet.wiche.edu 22 Military Students – Common Concerns Complaints Military Students: Tuition Assistance or Military Career Advancement Accounts – Defense Department. Montgomery or Post-9-11 G.I. Bill – Veterans Affairs Pell Grants or federal loans – Education Department “All other students can provide feedback about participating education institutions” – Consumer Financial Protection Bureau system.html

wcet.wiche.edu 23 Resources WCET State Authorization Webpage authorization WCET Frontiers Blog

wcet.wiche.edu 24 Resources 2016 State Authorization Workshops March 8-9,2016 Beginner to Intermediate Compliance Workshop Louisville, Kentucky June 14-15, 2016 Advance Topics Workshop Boulder, Colorado Sold Out

wcet.wiche.edu Contact Information 25 Russ Poulin Director, Policy & Analysis Cheryl Dowd Director, WCET State Authorization Network