The DRAFT version of our state-by-state list of regulatory agencies is now available on WCET’s state approval update page.  This document is a joint publication of WCET, the Southern Regional Education Board, the American Distance Education Consortium, and the University of Wyoming.  We have agreed to jointly do the research and openly share this information to help the distance education community.

If you read the many caveats in the document, you will note that this is a work that was assembled to drive to give some initial guidance for institutions that are wondering who to contact and what to look for in each state.  It is a “starter” list.

A confusing array of traffic lights
Ready! Set! Start!

Feedback on Our Draft and Sharing of Experiences

We do consider this a draft document and would like feedback to improve it.  We are sending it to the state regulators listed in the draft and we would like them to send us corrections by February 18.  We plan to create an updated document by the end of February based on those corrections.  In some states (Maryland, Ohio, and Utah) this will continue to be a moving target, as we have heard that legislation or regulatory changes may be coming.

We would also like to crowdsource the institutional experiences you are having in contacting the states and in deciphering how you should respond to each state.  We have created a form to collect your experiences and the experiences submitted will be openly shared so that you can learn from the experiences

Other Lists

Last week, Eduventures released state-by-state information in their presentation: “Online Learning Across State Boundaries:  Assessing State Regulation of Out-of-State Schools.”   You can obtain a copy of this document by contacting Blair Maloney at

For institutions researching the state approval issue, we recommend that you exam both the Eduventures document and our “Starter List.”  While there is overlap in some information, each report covers items not covered in the other.

The last I heard, the Dow Lohnes law firm is about ready to release their in-depth analysis.  That document will be available for a fee and I will let you know more about it once it is published.

This Ain’t Easy

I know that people don’t like to hear this, but each institution needs to perform much of the investigation on its own.  Given the mix of different regulations in each state and the mix of activities that an institution could be doing in that state, the permutations are too numerous to fit in any matrix.

A huge thank you to my colleagues at the partner organizations who conducted the research for this document.   We all went through the transformation from “how hard can this be” to “hey, this ain’t easy.”  I hope that you will remember that and appreciate the effort to help you as much as we can.

Russ Poulin
Deputy Director, Research & Analysis

WCET website:
Join WCET:

Picture Credit: AttributionNoncommercialShare Alike Some rights reserved by Squirmelia

1 reply on “State Approval: A “Starter” List”

IOWA – An Important Update

I received the following correction from Carolyn Small of the Iowa College Student Aid Commission:

An Iowa school that offers distanced education programs outside the state of Iowa shared with me your organization’s “State Approval Regulations For Distance Education Starter List,” just as an FYI, because I am the state authority for registering what we call “foreign” postsecondary institutions who are offering programs to Iowans. I know that you have a website available for state regulatory authorities to make corrections to information provided in this list for that state, but I thought I would call first to see how you would like to handle correction of all information for Iowa on this list.

It looks like someone mistakenly identified the Iowa Board of Regents as the regulatory authority over distance education programs offered to Iowa residents. The website for the Iowa Board of Regents provided on your list takes you to a site that provides an overview of the distance education programs offered by Iowa’s public universities.

I’ll share some information below about Iowa’s requirements for “state authorization” and ask that you give me a call to fill in any remaining blanks (contact information below).

To the extent that a school offering courses of instruction to Iowa residents is required to be registered or licensed in this state, the authority is my agency, the Iowa College Student Aid Commission. A school that is not otherwise exempt from registration (which includes nearly all institutions that originated in Iowa) may be required to register with my agency under Iowa Code Chapter 261B if it has a presence here. That would include a school offering distance education programs to Iowa residents, again, provided the school has a presence in the state. There’s more information about “presence” below.

Depending on whether the school has a presence here and the extent to which it is directly marketing to Iowa residents, the school may also be required to file evidence of financial responsibility under Iowa’s consumer protection law, Iowa Code Section 714.18. If it is a for-profit school that offers a degree, diploma, or license, the school may also be required to establish an Iowa tuition refund policy under Iowa Code Section 714.22.

In the last 6 months, we have expanded our policy relative to schools that must register under Chapter 261B. Updated, general information about who must register, including our current definition of “presence” in the state, who must file evidence of financial responsibility, and who must establish a state tuition refund policy is on our website at

The application for registering under Iowa Code Chapter 261B – or requesting a formal exemption from registration — is at

The application for filing evidence of financial responsibility under Iowa Code Section 714.18 – or requesting a formal exemption – is at

Any school that is offering purely distance education programs to Iowa residents and has no “presence” as we now define it is not required to register with the Commission. However, any school offering distance education programs to Iowa residents is strongly encouraged to contact me directly to discuss the school’s activities and operations in Iowa in detail. Often I find that discussion produces information about an aspect of the school’s operation that constitutes “presence.”

J. Carolyn Small
Postsecondary Registration Administrator
Iowa College Student Aid Commission
515 725 3413 (voice)
515 725 3401 (fax)

Comments are closed.


Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Join 2,438 other subscribers

Archive By Month

Blog Tags

Distance Education (326)Student Success (304)Online Learning (235)Managing Digital Learning (228)State Authorization (222)WCET (215)U.S. Department of Education (211)Regulation (203)Technology (169)Digital Learning (154)Innovation (125)Teaching (121)Collaboration/Community (114)WCET Annual Meeting (105)Course Design (103)Professional Development (100)Access (99)SAN (94)Faculty (90)Cost of Instruction (88)Financial Aid (84)Legislation (83)Completion (74)Assessment (69)Instructional Design (68)Open Educational Resources (66)Accreditation (65)COVID-19 (64)Professional Licensure (64)SARA (64)Accessibility (63)Credentials (62)Competency-based Education (61)Quality (61)Data and Analytics (60)Diversity/Equity/Inclusion (59)Research (58)Reciprocity (57)WOW Award (51)Outcomes (47)Workforce/Employment (46)Regular and Substantive Interaction (43)Negotiated Rulemaking (42)Policy (42)Higher Education Act (41)Virtual/Augmented Reality (37)Title IV (36)Practice (35)Academic Integrity (34)Disaster Planning/Recovery (34)Leadership (34)Artificial Intelligence (33)Every Learner Everywhere (30)State Authorization Network (30)WCET Awards (30)IPEDS (28)Adaptive/Personalized Learning (28)Reauthorization (28)Military and Veterans (27)Survey (27)Credits (26)Disabilities (25)MOOC (23)WCET Summit (23)Evaluation (22)Complaint Process (21)Retention (21)Enrollment (21)Correspondence Course (18)Physical Presence (17)WICHE (17)Cybersecurity (16)Products and Services (16)Blended/Hybrid Learning (15)Forprofit Universities (15)Member-Only (15)WCET Webcast (15)System/Consortia (14)Digital Divide (14)NCOER (14)Textbooks (14)Mobile Learning (13)Consortia (13)Personalized Learning (12)Futures (11)Marketing (11)Privacy (11)STEM (11)Prior Learning Assessment (10)Courseware (10)Teacher Prep (10)Social Media (9)LMS (9)Rankings (9)Standards (8)Student Authentication (8)Partnership (8)Tuition and Fees (7)Readiness and Developmental Courses (7)What's Next (7)International Students (6)K-12 (6)Lab Courses (6)Nursing (6)Remote Learning (6)Testing (6)Graduation (6)Proctoring (5)Closer Conversation (5)ROI (5)DETA (5)Game-based/Gamification (5)Dual Enrollment (4)Outsourcing (4)Coding (4)Security (4)Higher Education Trends (4)Mental Health (4)Fall and Beyond Series (3)In a Time of Crisis (3)Net Neutrality (3)Universal Design for Learning (3)Cheating Syndicates Series (3)ChatGPT (3)Enrollment Shift (3)Nontraditional Learners (2)Student Identity Verification (2)Cross Skilling/Reskilling (2)Virtual Summit (2)Higher Education (2)Minority Serving Institution (2)Title IX (1)Business of Higher Education (1)OPMs (1)Department of Education (1)Third-Party Servicers (1)microcredentials (1)equity (1)Community College (1)Formerly Incarcerated Students (1)