For the first time, WCET partnered with UPCEA and Sloan-C in providing recommendations on distance education policy.  We stated our positions in a letter delivered on Friday to Secretary Arne Duncan of the U.S. Department of Education.  In the letter we addressed the upcoming state authorization regulations that the Department is expected to release for public comment this summer.

Our hope is to influence the process prior to the Department publishing the regulations for public comment.  In the letter, we…The words "state authorization surrounded by all the state names.

  • Acknowledge the federal court’s recognition that the Department has the authority to issue such a regulation.
  • Express our concern that the Department’s intent to ask states to change their review procedures will cause confusion and added costs for students.
  • Present recommendations including that the Department return to the 2010 propose regulation that said that the Department would simply check that colleges are following state laws.  In addition, we also supported military exemptions (for active duty soldiers, their families, and Veterans Administration facilities), an exemption for institutions with only a few students in a state that would work better than the one currently proposed, and a requirement for notifying students about licensure requirements.  We also suggest that the Department work more directly with the states if it has concerns about existing state regulations and new federal regulations that would conflict with state requirements.

Thank You to Our Partners for Their Leadership

Mollie McGill and I wish to express our gratitude to Kathleen Ives (Sloan-C) and Robert Hansen (UPCEA-University Professional and Continuing Education Association) for their work and support in being co-sponsors of this letter.  We also with to thank our friends from the Distance Education and Training Council, National Council for State Authorization Reciprocity Agreements, Presidents’ Forum, and the United States Distance Learning Association for agreeing to lend their names as supporters.

We understand that not all of our institutions will agree with every recommendation in the letter.  We balanced several factors in our decision-making including:  existing state and federal laws, the Department’s need to protect federal financial aid funds, institutional burden in compliance, and protecting students as consumers.  The impact on students was paramount in our thinking at all times.

We Will Have a Greater Impact if Institutions Express Their Opinions

We invite you to weigh in.  You can do so now or use language from our letter.  If you prefer, you can wait until the proposed regulations are published (probably in July) and submit reactions to specific language then.  Or you can do both.

The Honorable Arne Duncan
Secretary of Education
Office of the Secretary
United States Department of Education
400 Maryland Avenue S.W., Room 7W301
Washington, DC 20202

We encourage you to let your opinion be known.

And I look forward to our groups working together in the future.Photo of Russ Poulin with baseball bat


Russell Poulin
Interim Co-Executive Director
WCET – WICHE Cooperative for Educational Technologies


If you like our work, join WCET!

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