Institutions nationwide are preparing for the implementation of the Department of Justice’s (DOJ) new digital accessibility regulations. It’s important and challenging to ensure compliance while still balancing an engaging learning environment.
At WCET, we understand the challenges of balancing federal guidelines, institutional priorities, and student needs. That’s why we’re excited to offer three timely events to help higher education leaders navigate these evolving requirements and explore strategies to humanize educational technology.
Understanding the rules is just the first step—putting them into practice is where institutions often face challenges. This session will dive into real-world applications, offering insights from institutions that have successfully implemented accessibility measures.
Speakers will share case studies, discuss common pitfalls, and provide strategies to ensure that your digital learning environments meet compliance standards while enhancing student access and success.
With the DOJ’s impending accessibility updates set to reshape how institutions approach digital content and services, proactive planning is key. In this Closer Conversation, accessibility and legal experts will break down the guidelines, discuss anticipated impacts on higher education, and offer clarity and guidance for moving forward. Members will have a chance to ask questions and share their experiences.
While accessibility compliance is critical, ensuring that educational technology fosters meaningful connections and student engagement is equally important. This year’s WCET Summit sessions will explore how institutions can integrate human-centered design into their technology strategies, making online and digital learning experiences more personal, inclusive, and effective. Experts will share best practices for leveraging EdTech tools in ways that prioritize student well-being, community building, and inclusive learning.
Why These Conversations Matter
WCET hosts a variety of events throughout the year – but as institutions strive to meet upcoming regulatory requirements, the three events listed above are increasingly important. Our goal with all WCET events is to provide essential guidance and a safe space for collaborative learning. Whether you’re a campus leader, instructional designer, faculty member, or accessibility advocate, these sessions will equip you with the knowledge and strategies to navigate accessibility challenges and create more engaging, student-centered digital learning environments.
We encourage you to join the conversation and bring your questions, experiences, and insights. It’s time to make sure your institution stays ahead of the curve on accessibility in digital learning and the best ways to balance that with human-centered teaching and learning. Learn more and register todayfor these great events on WCET’s Events Page.
Make sure to tune into WCET for more on these topics, including an upcoming accessibility theme of the month and related events like a webcast co-presented with Every Learner Everywhere and Teach Access!
This post was written by Lindsey Downs with brainstorming and outline assistance from ChatGPT
Distance education has come a long way since WCET conducted a survey to better understand the relationship between the cost and price of distance education in 2016. The results of this survey were published in the 2017 study Distance Education Price and Cost Report. That survey found that although 75% of respondents indicated that distance education and face-to-face students paid the same tuition, once fees were added into the equation, the majority of distance education students, 54.2%, paid more for their education than their face-to-face counterparts. Survey respondents also indicated that distance education generally costs more, but there are instances when it costs less if cost reduction is a specific goal of the distance offering.
After notable changes to the digital learning landscape by a global pandemic and the explosion of emergency remote instruction that came with it, we have seen increased interest in student enrollment in online courses. In 2024, IPEDS reported that 63.94% of all students were enrolled in at least one distance education course. Although this is down from COVID-era levels, it is significantly higher than pre-pandemic levels.
This high number of students taking at least one distance education course and the continued increasing price of higher education speaks to the need to revisit the study and determine what, if any, connection between the price and cost of distance education exists.
Invitations to participate in the survey went to all WCET members and distance education leaders listed in the Higher Education Directory.
Survey participants were instructed to submit only one response per institution. There were 171 unique institutional responses.
Although we had hoped for greater participation in the survey, this is similar to the response to the 2016 survey. Because of the low number of responses, we cannot generalize the survey findings to all of higher education.
However, given the high number of public institutions represented in the survey, 73% of all respondents, the data may be especially indicative of public higher education.
A Note About Definitions
In our work in this area, we define cost as the amount of money that the institution spends to create, offer, and support instruction. Price is defined as the amount of money that is charged to a student for instruction and includes tuition and fees. We also used the IPEDS definition of distance education.
Conclusions on Cost and Price
The report draws seven conclusions on the cost and price of distance education.
The majority of distance education courses, 55.6%, are funded the same as face-to-face courses. This may indicate that distance education is becoming a more mainstream form of instruction and is less often segregated in self-funded units. In 2016, only 48.7% of respondents indicated that distance education courses were funded the same as face-to-face courses.
Differences in tuition and fees between distance education and face-to-face instruction often correspond with the level of the institution. The higher the Carnegie classification, the more likely that different policies for face-to-face and distance education exist. Still, the overwhelming majority of institutions, 63.2%, reported no different tuition and fee policies. This is over a 10 percentage-point increase since 2016 and suggests that distance education is being treated much like face-to-face instruction and may suggest the growing integration of distance education into the institution.
Modality is increasingly irrelevant when determining the price of distance education. A little over 74% reported that tuition is the same regardless of modality. However, differences in distance education fees do exist. Even though approximately half reported that distance education and face-to-face instruction had the same fees, almost 31% reported that distance education fees were higher.
The costs of distance education are normalizing when compared to face-to-face instruction. In 2016, in nine of the 22 cost categories respondents were asked about, distance education costs were more than face-to-face costs. However, in 2024, only six (regulatory costs, technologies, instructional design, creation of learning materials, assuring accessibility and ADA compliance, and faculty development) were more expensive than face-to-face instruction.
The total price (tuition and fees) of distance education is beginning to align with face-to-face instruction. A little over 34% reported that the total price of distance education was the same as that of face-to-face instruction. Still, more than a third (39.6%) reported that the total price of distance education was higher, and almost a quarter (24%) said that it was less than face-to-face. When compared to 2016, this indicates that we are beginning to see an alignment with face-to-face instruction. In 2016, 54.2% indicated that the price of distance education was greater, 26.8% the same, and only 19% indicated that it was less than face-to-face instruction.
Distance education is not, however, resulting in significant cost savings. Across the 21 categories in 2024’s survey, there were no categories where the majority of distance education courses cost less than face-to-face instruction.
Price continues to be disconnected from cost. In 2016, 10.6% of respondents indicated that the price of their distance education courses was connected to their cost, while only 10.9% of the 2024 respondents reported a connection between price and cost.
We are aware that some legislators continue to believe that distance education should cost less than face-to-face instruction. There was a strong consensus among our respondents that distance education is not inherently cheaper and may require equal, if not more significant, investments to create quality courses. One respondent succinctly put it, “Low cost equals low quality.”
Respondents indicated several hidden costs that policymakers may overlook, including:
Technology infrastructure;
Instructional design;
Student support;
Compliance and regulations;
Increased time investment for course preparation;
Interaction with students; and
Providing feedback.
As institutions turn to distance education to recruit more students and improve student access regardless of time and place, better understanding the costs of those distance education courses is critical. As one respondent wrote, “It is a misunderstanding to think of online classes as a commodity or product that can be ‘served’ to limitless numbers of students once developed. (We call this the ‘just push play’ myth.) Educating one student online, through regular and substantive interaction, requires just as much instructor effort and time as educating one student in the classroom.”
Explore more of WCET’s work on this critical topic on our Cost and Price Practice page, featuring past reports, related blog posts, articles, and additional resources.
The two organizations achieve this by providing leadership, guidance, and support as we work closely with states, higher education institutions, policymakers, and other organizations participating in various aspects of distance learning.
It’s not uncommon for SAN staff or NC-SARA staff to be asked about the relationship between the two organizations, where they overlap, what is unique to each, the value they bring, and how they work together and support one another. We will touch on those topics below but defining State Authorization Reciprocity Agreements (SARA) is an important preliminary step.
SARA: is an agreement amongst member states, districts, and territories that establishes comparable national standards and streamlines regulations, fees, and approvals for institutions offering interstate distance education programs.
49 member states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands all voluntarily joined SARA, and apply for renewal of their membership every two years.
More than 2,400 institutions, all accredited by agencies recognized by the U.S. Department of Education, participate in SARA. They apply for renewal of SARA participation each year.
NC-SARA: is a private nonprofit [501(c)(3)] organization that, in partnership with the four regional education compacts, coordinates the implementation of SARA nationally.
NC-SARA helps states, institutions, policymakers, and students understand the purpose and benefits of participating in SARA.
SAN: was established to serve post-secondary institutions and organizations nationwide by providing training, support, and opportunities to collaborate while navigating regulatory compliance for out-of-state learning activities.
SAN is a division of WCET, the WICHE Cooperative for Educational Technologies.
WCET: The WICHE Cooperative for Educational Technologies is the leader in the practice, policy, and advocacy of digital learning in higher education. WCET brings together colleges, universities, higher education organizations, and companies to collectively improve the quality and reach of digital learning programs.
WCET is a unit of WICHE, the Western Interstate Commission for Higher Education.
WICHE: The Western Interstate Commission for Higher Educationis a regional, nonprofit organization whose membership includes 15 western states as well as the U.S. Pacific Islands and freely associated states. WICHE and its member states and territories work to improve access to higher education and ensure student success.
While there is lots of foundational information to consider, it is also important to understand the early days of online learning at the postsecondary level.
Distance Education in the Early 2000s
The growth of online education in the early 2000s led to a patchwork of state regulations surrounding distance education offerings. Institutions found it challenging to navigate these requirements, which varied widely by state. To further complicate matters, in late 2010, the U.S. Department of Education released the first federal regulation for state authorization of distance education.
The purpose of the regulation was to provide important consumer protections for learners who participated in interstate distance education. Although the original language of federal regulation 34 CFR 600.9(c) was eventually vacated by federal courts, it was the impetus for what is now the even more complicated and ever-evolving landscape of institutional compliance related to out-of-state postsecondary educational activity.
SAN and NC-SARA are Formed
Established in 2011 by WCET, SAN emerged to provide respite and to serve and support institutions/organizations in their quest to navigate the complex world of distance education compliance. SAN is now a vast network of more than 900 member institutions and organizations and remains a leader in authorization for distance education.
In December 2013, just a couple of years after SAN was formed, NC-SARA was established to help support the regional education compacts in the implementation of the reciprocity agreements (SARA) across the nation. States began joining SARA in 2014, starting with Indiana. Valley City State University in North Dakota was the first institution to be approved for participation in SARA, joining in April 2014. By July 2019, 49 states and three territories were SARA members. As of 2024, SARA has over 2,400 participating institutions.
What are the Benefits of Participating in SARA?
Students benefit from increased access to distance education programs across state lines, and in many cases, improved consumer protections that they would not have if SARA did not exist. By encouraging strategic coordination and communication between and among SARA member states and providing a uniform set of policies for student consumer protections that otherwise would vary state-by-state, SARA streamlines state authorization processes for out-of-state institutions and helps reduce associated costs and bureaucracy for both states and institutions.
SARA’s work includes:
Advancing efforts to align core elements and requirements of SARA reciprocity across the SARA member states.
Expanding consumer protections by facilitating state-led SARA policy changes.
Ensuring effectiveness and continuous improvement of the collaborative partnership with the SARA community.
What are the Benefits of Participating in SAN?
SAN helps its members gain a better understanding of state and federal compliance requirements, fosters communication and collaboration, and provides educational and professional development opportunities to its members. SAN’s participation in and contributions to the field of distance education compliance are vital.
The organization takes very seriously its role in conducting and disseminating critical research, advocating on behalf of its members, and keeping institutions informed about changes at the state and federal levels that impact distance education and state authorization.
SAN is proud of its reputation as an organization that offers its members timely support, not only to SARA-participating institutions but also to institutions that, because they do not participate in SARA, are required to secure approval to offer distance education in other states through traditional state-by-state processes.
SAN (and WCET) are known nationally as staunch defenders of distance education. For example, Russ Poulin, Former Executive Director, WCET and Vice President for Technology-Enhanced Education for WICHE, was selected to be the negotiator representing the distance education community in the U.S. Department of Education’s 2014 Negotiated Rulemaking process, and was also a member of the Distance Learning Subcommittee in the 2019 Negotiated Rulemaking process.
SAN tirelessly champions the interests of member institutions in discussions about state authorization policies and regulations, and when working with state and federal government to influence legislation and practices that affect online education.
Additionally, SAN compliments institutional state approvals through reciprocity plans (such as SARA), as well as providing continual support to institutions that are required to garner state institutional approval through traditional individual state-by-state processes.
Our Impact in the Field
NC-SARA Highlights
NC-SARA collects, compiles, and shares SARA exclusively distance education enrollment data and out-of-state learning placement data that is publicly available. SARA enrollment data from 2023 shows that over 1.6 million students attended out-of-state institutions exclusively via distance education through SARA in Fall 2023, and more than 430,000 students participated in out-of-state learning placements such as clinical rotations, student teaching, and internships that year. NC-SARA also collects, maintains, and publishes information regarding SARA student complaints, and helps facilitate the SARA Policy Modification Process that puts states in control of SARA policy changes.
NC-SARA helps support its state members by convening an annual in-person SARA SPE conference as well as several virtual meetings each year for all 52 member states and territories to engage in discussion around SARA and related topics. NC-SARA offers grants of up to $7,500 per year to SPE staff, providing funding for states to participate in critical professional development and host in-state convenings with their institutions. NC-SARA also provides the SARA Learning Station as a one-stop shop to access resources to learn about SARA.
To assist institutions that do not participate in SARA or wish to operate in a SARA member state beyond the scope of SARA, NC-SARA provides The State Authorization Guide, a collection of state laws, regulations, and requirements covering activities that require authorization. The guide also includes application processes, costs to comply, and more, and is compiled from information submitted by state authorization regulatory agencies in each state, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands.
In addition, to help institutions as they seek to comply with federal professional licensure requirements, NC-SARA provides a Professional Licensure Directory with contact information for state professional licensure boards for counseling, nursing, psychology, social work, and teacher education programs, which are the programs with the highest enrollment based on data provided by SARA-participating institutions.
The network produces guides, tool-kits, and other resources that assist institutions in understanding and implementing state approvals.
Provided hundreds of in-person and virtual opportunities for training and support:
SAN offers in-house and campus-based training and workshop opportunities for institutional staff to be informed about changes in laws and regulations affecting distance education.
This includes both asynchronous and synchronous training in various formats, including workshops, monthly calls, and webcasts.
Provided 13 years of policy influence:
SAN advocates for policies that support equitable access to education and streamlined regulations that benefit both institutions and students.
Aided in facilitating student access:
By helping institutions navigate state regulations, SAN expands access to education for students across different states, enabling them to enroll in postsecondary programs without unnecessary barriers.
Both NC-SARA and SAN contribute to a more efficient and effective landscape for online education, benefiting institutions and students alike.
Common Goals of NC-SARA and SAN
NC-SARA and SAN, housed in adjacent buildings in Boulder, Colorado, have worked together for more than a decade, share common goals, and are regarded as trusted leaders in the field. Even more than their close physical proximity, both NC-SARA and SAN take pride in their roles as leaders.
Marianne Boeke, president of NC-SARA shared, “WCET, SAN, NC-SARA staff, and the SARA community have worked closely together since the beginning. In the early days before there were SARA staff, SAN helped present what SARA was and how institutions could participate. WCET created the first resource for state-to-state authorization that eventually led to the State Higher Education Executive Officers Association (SHEEO) surveys in 2011, which are now maintained and housed by NC-SARA. SAN not only helps NC-SARA staff, but they also assist the regional education compacts, SPEs, and institutions. They attend SARA state meetings, regional steering committee meetings, and the SPE Annual Conference. WCET and SAN staff also continue to collaborate with NC-SARA staff on webinars. They can talk to any audience. They do it all.”
Boeke recently shared her hopes for the future: “We would appreciate SAN’s help revamping the State Authorization Guide and looking at our website from an outside perspective/institutional perspective to help us determine how to make it more user-friendly. We hope SAN staff will continue to present with us and keep us updated on higher education regulations that are adjacent to us, and we hope for their continued partnership throughout the negotiated rulemaking process, including implementing new policy and navigating any challenges.”
Cheryl Dowd, Senior Director with the SAN & WCET Policy Innovations, is proud of the ongoing relationship between the two organizations. She reminds us that NC-SARA and SAN have always been deeply entrenched and continue to work collaboratively.
As an example, prior to NC-SARA obtaining its 501(c)3 status in 2015, NC-SARA was financially managed by SAN’s parent organization, WICHE. Dowd explains, “This interim arrangement facilitated the management of payments, payroll, and employee benefits while NC-SARA awaited the granting of its own 501(c)3 status. Initial funding for NC-SARA’s operations was secured through a grant from the Lumina Foundation.” Dowd also notes that SAN hosted NC-SARA webinars until 2018, when NC-SARA obtained their own webinar platform.
Dowd continues, “NC-SARA staff members and/or SARA Regional Directors present biannually at each SAN Workshop. What’s more, SAN staff regularly present on NC-SARA webinars, SARA meetings, and Regional Steering Committees (RSC) meetings.” She continues, “SAN and NC-SARA staff have collaborated on presentations at several national conferences, and SAN also participates in the SARA Policy Modification Process.”
Russ Poulin, Former Executive Director of WCET and Vice President for Technology-Enhanced Education for WICHE, who has been around since the conceptualization phase of both NC-SARA and SAN, is also proud and supportive of the relationship and history between the two organizations: “It has been a great symbiotic relationship. SARA is part of the state consumer protections for students and also creates a path for institutions to operate in participating states. SAN addresses the multitude of issues that institutions face in a state that is not covered by SARA, such as professional licensure, federal regulations (Education, Defense, Veterans, Justice), and managing compliance activities. It is a positive partnership. Each working in their own lane, but working collaboratively, has helped all of higher education.”
Poulin continues, “SAN staff are often in contact with SARA leadership, whether at NC-SARA or the four regional higher education compacts. Through its institutions, SAN staff often learn of regulatory issues that its members or their students have in distance education that crosses state lines. SAN has been able to use that information to suggest improvements in SARA policies or procedures. WCET and SAN staff have served on several workgroups and have made numerous presentations for NC-SARA or regional compact events.”
Another Important Partner: NASASPS
Both SAN and NC-SARA have maintained ongoing collaborations and working relationships with the National Association of State Administrators and Supervisors of Private Schools (NASASPS) team. Cathie (Cam) Maeyaert, Director of Private Postsecondary Institutions with the Texas Higher Education Coordinating Board, Vice President of the 2024-25 NASASPS Board of Directors, and NC-SARA Board Member, shared her thoughts on these partnerships:
Maeyaert recalls, “NASASPS and SAN have partnered for several years on the NASASPS annual conference that occurs in the Spring of each year. Cheryl Dowd has been a great resource in assisting NASASPS to develop topics that will be timely and helpful to institutions that are attending the conference. SAN has also provided speakers for general sessions at the conference. NASASPS values the deep knowledge that SAN and WCET staff bring to these sessions.”
She continues, “The partnership between NASASPS and SAN has resulted in NASASPS being able to connect with more institutions and allowing the NASASPS members to get to know the institutions and their personnel. The relationships built because of the synergy that NASASPS and SAN have created benefits for all, whether it is in formal conference sessions or the ability to ask and answer questions ‘off-line’ in a more relaxed, one-on-one setting.”
“NASASPS and NC-SARA have also worked together. Several years ago, we coordinated the NASASPS fall workshop and NC-SARA SPE conference to run back-to-back so that state regulators could combine travel. We hope to do this again in the future. NC-SARA staff have been invited to attend the NASASPS conference and present for several years. It is always valuable to have NC-SARA staff provide updates and explain any changes on the horizon. We appreciate the time NC-SARA staff has taken to join us to provide information.”
“NASASPS opened up its regular membership to SARA SPEs within the last two years. Feedback from several SPEs has indicated that attending NASASPS events allows them to learn more about state regulations that they may not get within their state, especially if the SPE is not part of the state higher education agency and therefore does not have a lot of contact with their state colleagues. NASASPS is enriched by having these SPEs as regular members.”
Concluding Thoughts
SARA offers significant benefits to both institutions and students. It provides a more streamlined and consistent approach to state authorization, allowing institutions to expand their reach and students to access a broader range of programs while maintaining high standards of quality and accountability. Ultimately, SARA fosters a more accessible and efficient higher education landscape for distance education.
SAN provides institutions with an efficient, centralized way to navigate the complex landscape of state authorization, particularly for distance education programs. By offering streamlined processes, resources, real-time updates, and a platform for collaboration, SAN helps institutions save time, reduce costs, stay compliant with state regulations, and confidently offer students a broader range of educational opportunities.
Both NC-SARA and SAN are national leaders in distance education compliance. These organizations are widely recognized for their expertise and collaboration. As trusted neutral parties, NC-SARA and SAN will continue to work with stakeholders to address complex distance education compliance issues and deliver viable solutions.
This post was written by Sarah Levy, NC-SARA, and Jana Walser-Smith, SAN
T’was the final weeks of December when most of higher education was not stirring – except for the U.S. Department of Education (Department). The Department was preparing gifts announcements finalizing the regulatory issues from the Winter 2024 rulemaking.
In late December, the Department released two important announcements:
These announcements separate the Winter 2024 issue areas discussed during negotiated rulemaking into two groups.
1 – Formal End of State Authorization, Cash Management, and Accreditation Rulemaking Process
This termination announcement formally ends the rulemaking for the issue areas of State Authorization, Cash Management, and Accreditation. In order for new rules on these issues to move forward, a new rulemaking must be initiated to develop or amend regulations on these issue areas.
2 – Release of the final regulations for Distance Education, Return to Title IV (R2T4), and TRIO Programs
The second announcement is the release of the final regulations for Distance Education, Return to Title IV (R2T4), and TRIO Programs. It is important to note that several provisions, which many of you addressed in your public comments, were removed from the final regulations. The Department did not include final regulations requiring distance education attendance taking, ineligibility of Title IV aid for asynchronous clock hour programs, and the definition of virtual location.
The Department acknowledged that the receipt of so many public comments during the 30-day comment period influenced the final regulations. Despite the Department’s belief that 30 days is adequate, we appreciate the community coming together so quickly despite the brevity of time.
Rulemaking Process Recap
The Department convened a negotiated rulemaking committee that met in Winter 2024 on the six issue areas shared above. At the end of the committee meetings in March 2024, the committee members did not come to an agreement (consensus) on the language of new and amended rules, except for the TRIO programs. When there is no consensus from the committee, the Department then writes the proposed rules.
In July 2024, the Department released proposed regulations on three of the six issue areas:
Distance Education,
Return to Title IV, and
TRIO programs.
Upon release of the proposed regulations, the public was invited to participate in a 30-day public comment. After the public comment, the regulatory process included the Department’s review of all public comments, development of responses, and writing of the final rules. On December 9, 2024, the final draft package of regulations was sent for the executive branch review by the Office of Management and Budget (OMB) Office of Information and Regulatory Affairs (OIRA). This served as the last step before final regulations were publicly released. Despite a process to include public testimony for the OIRA Review called an EO 12866 meeting, OMB canceled the SAN and WCET request for a meeting. We observed on the OMB/OIRA website that no EO 12866 meetings were taken on this final regulatory package. Final regulations were released as the unofficial version on December 30, 2024, and published in the Federal Register on January 3, 2025. The effective date of the regulations is July 1, 2026. However, the distance education data reporting into the National Student Loan Data System (NSLDS) will not be required until July 1, 2027.
The remaining issues of State Authorization, Accreditation, and Cash Management did not move forward in the regulatory process, and no proposed rules were released. These issue areas are now formally discontinued from the rulemaking process and would require new negotiated rulemaking on the issues for any changes to existing regulations.
Analysis of Program Integrity and Institutional Quality: Distance Education and Return of Title IV, HEA Funds – New Rules
The Department indicated in the preamble of the Federal Register announcement that public comments persuaded them not to finalize provisions related to the definition of virtual location, ineligibility of asynchronous clock hour programs for Title IV aid, and required distance education attendance taking. To be clear, there are no new regulations on those provisions listed above.
New Final Provisions –
Definition of Distance Education Course (34 CFR 600.2)
New Language-
A course in which instruction takes place exclusively as described in the definition of distance education in this section notwithstanding in-person non-instructional requirements, including orientation, testing, and academic support services.
The purpose of the new definition of Distance Education Course is to clarify what in-person non-instructional requirements that are to be considered as part of a distance education course.
The term “residency experiences” was removed from the proposed regulations version of the definition. The Department acknowledged public comments expressing that a definition that included “residency experiences” would be inconsistent with the IPEDs definition of a distance education course and could create confusion because “residency experience” indicates an undefined period for in-person coursework in a particular class.
Reporting Enrollment in Distance Education or Correspondence Courses (34 CFR 668.41 (h))
New Language-
(h) Reporting of student enrollment in distance education or correspondence courses. For each recipient of title IV, HEA assistance at the institution, the institution must report to the Secretary, in accordance with procedures established by the Secretary, the recipient’s enrollment in distance education or correspondence courses.
The purpose of the reporting was expressed in the preamble, “It is the Department’s belief that all parties—the Department, Congress, researchers, institutions, students, and the general public—can benefit when they have program outcome data by modality when making decisions.” The Department indicated that the final rules set an implementation date of July 1, 2027, to require institutions to report this information to the National Student Loan Data System (NSLDS).
The Department received public comments expressing concern over the possibility of future data analyses that might look at the effectiveness of a modality without also taking into consideration other student characteristics that might impact student success. Commenters shared that additional factors must be considered to address differences in the student populations. Although not stated in regulation, the Department assures the public in the preamble that a variety of demographic factors would be considered when developing policies around distance education. Specifically, the Department states, “With respect to the use after collection, the Department would not evaluate information about distance education in a vacuum.” We welcome the new data collection and are pleased to see the Department take our and others’ comments that nuanced analysis of any student success data is needed. We look forward to working with the Department and the distance education community in developing nuanced research on all the characteristics that can impact student success in various modalities.
Determination of Withdrawal Status (34 CFR 668.22(b)(2)) – 14-day rule
Amended Language–
(b) * * * (2) An institution must, within 14 days of a student’s last date of attendance, document a student’s withdrawal date determined in accordance with paragraph (b)(1) of this section and maintain the documentation as of the date of the institution’s determination that the student withdrew.
The purpose of this 14-day rule is to set a regulatory timeframe to document a student’s withdrawal for purposes of returning Title IV funds. The preamble indicates that the Department is codifying in regulation what has been in guidance since the 2005-06 award year for institutions that are required to take attendance. This requirement applies regardless of modality.
The Department indicates that this provision of the 14-day time frame only applies to institutions required to take attendance under 34 CFR 668.22 (b)(3). Commenters, who were primarily concerned about the proposed requirement for distance education attendance-taking, expressed concern about this 14-day provision. The commenters interpreted that the proposed regulation directed that a student must be administratively withdrawn after 14 days of non-attendance. The Department dismissed this notion by indicating that guidance (not cited) directs that the institution has an additional 45 days before any calculated return must be made. Further, if the student returns within that 45-day time frame, no further action is required. We are pleased to see the Department provide this clarification and that institutions would not be required to administratively withdraw a student after 14 days of non-attendance.
Future of the Rules
The future of the rules and provisions raised during the Winter 2024 rulemaking will fall into two general categories.
First, a new negotiated rulemaking would provide a future pathway to create new or amended rules for State Authorization, Cash Management, and Accreditation. Additionally, all provisions not finalized from the proposed regulations for Distance Education, Return to Title IV, and TRIO Programs can only be raised again through a new negotiated rulemaking. The Department indicated that further assessment and evaluation would benefit the possible future development of regulations on these issues.
Second, the final regulations announced in the Federal Register on January 3, 2025, will become effective on July 1, 2026, with the data reporting regulations effective as of July 1, 2027. The new administration does have access to tools to deregulate. As previously discussed, regulatory challenges could occur through the Congressional Review Act, Executive Orders, and possible court challenges. Additionally, the next administration could initiate a new negotiated rulemaking.
However, institutions must prepare for compliance with new regulations and continue compliance with existing regulations despite discussions of potential deregulation. As we have maintained, the rules are the rules until they are no longer the rules. WCET and SAN will continue to follow and report to you any activities that affect new or existing regulations.
Final Thoughts
We are glad to see the finalization of the Winter 2024 rulemaking process. The final regulations appear to address concerns raised by our public comments and those of our members. To be clear, SAN and WCET maintain a common goal with the Department to ensure student protection and success. Our initial concerns, which we raised in our public comment at the outset of this rulemaking in April 2023, included:
Additional consumer protections are needed, but they need to be targeted to the areas of risk rather than targeting all of distance education.
All instructional modalities should be treated the same.
The Department should provide clear and concise regulatory language.
Thank you to all who provided input during this negotiated rulemaking process to help us elevate your views to the Department. WCET and SAN will continue to monitor the developments and report them to you. Stay tuned!
This post was written by Cheryl Dowd and Van Davis, WCET
Every few years, WICHE (WCET’s parent organization) publishes a pivotal analysis of high school graduate projections for the United States. This analysis, presented in WICHE’s Knocking at the College Door report, tells the story of shifting demographics, evolving opportunities, and the need to adapt to meet students wherever they are.
Of key interest this year – the most recent publication is the first Knocking report published post-COVID-19 pandemic. It takes into account new workforce demands and challenges of equity and access in higher education.
Today, we’re excited to give you a quick overview of the new report, plus some thoughts we had during WICHE’s webcast announcing the release, which took place on December 11, 2024.
Incredible interactive data visualizations from the team at WICHE where you can explore data behind the key findings (such as profiles by geographic location, regional variation under national trends, a COVID-19 impact visualization, and more) – wiche.edu/knocking/data-visualizations/
PRIMARY FINDINGS!
This year’s Knocking at the College Door reports five primary findings – here are our thoughts on each of those. See the report for more details on each of these.
In 2025, the total number of high school graduates is projected to be 3.9 million students yet the number of graduates is projected to decrease to 3.37 million by 2041.
This trend is primarily driven by a decrease in birth and fertility rates that closely parallels the projected decrease in high school graduates.
High school retention and completion rates, as measured through graduation rates, are projected to be stable.
The number of White high school graduates is projected to decrease by 26% by 2041, while the number of Black graduates is projected to decline by 22%. Hispanic graduates are projected to increase by 16%, and Multiracial graduates are projected to increase by 68%.
Students identifying as American Indian/Alaska Native graduates are projected to decline by 41%, from 30,000 in 2023 down to 18,000 in 2041. Additionally, the number of Asian/Native Hawaiian and other Pacific Islander graduates is projected to decrease by 8% – 10%.
While the number of high school graduates in the South is projected to increase from 1.4 million to 1.5 million by 2041, Western graduates are projected to decrease from 934,000 to 745,000, Midwestern graduates from 768,000 to 639,000, and Northeastern graduates from 612,000 to 518,000.
While the “enrollment cliff” is an often-used metaphor – the report’s authors advise that the reality will be a slower and steadier shift of student demographics, which will have important implications on higher education, workforce training, and state and federal government.
WHAT CAN HIGHER EDUCATION DO
As stated in the report, “Despite these worrying trends, a peak then decline in the number of high school graduates need not spell doom for institutions across the country…” (Knocking, 66).
The report’s authors were careful to emphasize that higher education has some agency despite the projected decline in enrollment.
They suggested several evidence-based practices that could lead to improved higher education enrollment and graduation rates. For example, a 5% increase in the college-going rate for recent high school graduates could begin to offset the projected college enrollment decline.
Enhanced student advising and financial aid programs like the CUNY ASAP program and Montana 10.
Early admissions programs.
Informing students of their financial aid packages earlier in the admissions process.
Prior learning assessment that provides learners with experiential credit for adult students.
“Z Degree” programs that leverage open educational resources to provide zero learning material cost degrees.
Basic needs programs and benefit navigator programs like the Oregon program.
Final Thoughts
In addition to the report and its interactive dashboards, WICHE is also planning to analyze high school graduation data for the American Territories and Freely Associated States and examine the impact of gender on the projections. Additionally, a webinar series on evidence-based interventions is being planned for 2025. Make sure to check the Knocking at the College Door website for more information on future analysis and events.
All of us at WCET congratulate the team behind this year’s Knocking at the College Door report – as always you’ve delivered the higher education community vital information to help us all better understand how we can best support students moving forward.
In my role here at WCET, I’m always inspired by the innovative ways institutions tackle challenges to support their students. For rural colleges, overcoming barriers like limited broadband and digital literacy requires creativity, resilience, and the right tools. Originally from Idaho and now living in Montana, I’m particularly interested in how our more rural institutions face such issues.
Today I’m happy to welcome Rachael Hardiek with BibliU, who dives into how rural institutions are reimagining education with tech-enhanced solutions, ensuring students in even the most remote areas can succeed. These solutions include designing learning materials in a mobile-first mindset and supporting new digital literacy programs.
For rural colleges, offering high-quality education often hinges on one thing: access. For students in remote areas, physical distance, limited broadband, and digital literacy challenges can turn the simple act of attending class into a feat of endurance.
But today, advancements in technology are rewriting the educational narrative for rural students. By harnessing tech-enhanced learning tools, colleges in rural areas are expanding the reach of their programs, creating flexibility, and fostering student success in innovative ways.
This shift goes beyond integrating technology—it’s about rethinking education to serve every student, everywhere.
The Connectivity Conundrum
For many rural students, connectivity remains a formidable obstacle. Despite recent advances, millions of Americans in rural areas still lack reliable, high-speed internet, especially in remote or mountainous regions. Students in these situations can struggle to access online courses, complete assignments, or even communicate with instructors. This connectivity gap has a ripple effect, impacting educational engagement, retention, and outcomes.
Additionally, limited internet access often compounds the device access gap. For some students, mobile phones are the only connection to online resources, while laptops and tablets remain out of reach. Rural colleges, therefore, need solutions that are mobile-friendly and bandwidth-conscious to ensure students can stay engaged, regardless of their connectivity or equipment.
Digital Learning tools and applications can be used to help students gain access to a wide-array of educational material. It’s important that these tools work seamlessly across devices and are accessible even on mobile networks so that limited internet doesn’t limit the learning experience.
Making Mobile Learning Work
To bridge the tech divide, rural colleges can lean into mobile-optimized content. Mobile networks are often more reliable in areas with inconsistent broadband, with smartphone access common even in some of the most isolated areas. As current trends in highereducation show, mobile device ownership is becoming even more extensive. By focusing on mobile-enabled solutions, rural colleges can make it possible for students to study anywhere, anytime.
Platforms like BibliU play a pivotal role in supporting flexibility by offering digital textbooks and resources that students can easily access with just a mobile device. The shift from physical textbooks to digital-first resources is a game-changer for rural students. It lightens their load, reduces costs, and—importantly—opens up learning for those who rely on mobile data. By optimizing for mobile, rural institutions can ensure that students with limited internet or device access are not left behind.
Many rural colleges and their partner organizations are developing digital literacyprograms that target the unique needs of their students. From workshops on navigating online classrooms to security skills, these programs build a solid foundation that empowers students to learn and engage. Faculty training is equally important in this endeavor. Colleges that offer continuous professional development in digital skills ensure that faculty can confidently integrate tech into their teaching and support students in doing the same.
A vendor like BibliU that offers additional training and support throughout the transition to digital resources is imperative for ensuring success across campus. With BibliU, students and faculty have access to resources they can understand and use confidently. The platform is designed to be intuitive, requiring minimal setup or advanced technical knowledge—ideal for students who are becoming increasingly comfortable with digital tools.
Flexible Learning Models for Every Schedule
For many rural students, balancing family responsibilities, jobs, and class schedules is part of everyday life. Flexibility, therefore, is essential. That’s why many rural colleges are embracing hybrid and blended learning models that offer students the freedom to attend classes in ways that fit their lives. Hybrid learning combines online and in-person instruction, while blended models allow students to engage in real-time or catch up later on their own schedules.
Asynchronous learning options can make a significant difference for students with non-traditional schedules or limited internet at certain times. Colleges are also implementing low-bandwidth solutions that reduce data needs, such as downloadable resources and compressed video content, so that connectivity issues won’t interrupt learning.
Charting a Path to a More Connected Future
The potential of tech-enhanced learning for rural colleges is vast, and new developments in technology promise even greater access. As 5G and satellite internet services expand, connectivity gaps in remote areas could begin to close, bringing a new wave of opportunity. For rural colleges, the future holds the promise of even more immersive learning tools like virtual reality (VR), which can simulate hands-on experiences in ways previously impossible in a remote setting.
Creating a tech-forward educational model that is inclusive and flexible requires funding and thoughtful policy. Rural colleges can’t do it alone; they need targeted support, whether from state programs, federal initiatives, or private grants, to fully develop the tech infrastructure necessary for digital learning.
Partners like BibliU are essential in this journey, offering scalable digital resources that are accessible, affordable, and easy to implement. By supporting rural colleges in providing digital-first, cost-effective course materials, BibliU is helping students access essential learning resources and achieve success from day one.
Since 2015, the awards have recognized the achievements of higher educational institutions and organizations nationwide that have raised the bar when developing comprehensive and viable solutions to challenging distance education compliance/state authorization issues.
This year, SAN honored seven winners in three categories:
Compliance Innovations: Institution policy, tools, compliance teams, or other inventive or novel compliance management process;
Licensure Programs: Notifications and disclosures for professional licensures in each state; and,
Location: Identifying student location for regulatory compliance and reporting requirements.
The SANsational Award Process
SAN offers members the opportunity to self-nominate, which includes providing specific information on their solution to the regulatory issue their project/process addresses. Details such as data related to implementation timelines, costs, stakeholder requirements, etc., are often noted within each statement of interest. All submissions are then reviewed by the SANsational Awards Committee, a team of well-respected Distance Education Compliance Professionals. The committee evaluates the submissions in four key areas by ensuring that:
The solution meets the requirements and the needs of state and/or federal regulations, the institution, and students.
The submission demonstrates a clear, comprehensive, practical solution to meet compliance requirements.
The project exhibits the capability of being adapted or replicated as a model for others.
The project addresses the specific focus of the category chosen.
Accordingly, the SAN Team extends our sincere gratitude to this year’s Awards Committee, for carefully reviewing and considering all submissions and for providing guidance and leadership when selecting our 2024 award recipients. The 2024 SANsational Awards Committee includes:
Jeannie Pauline Yockey-Fine, J.D., General Counsel, NC-SARA.
About the winners…
Again, this year, SAN presented awards for seven stellar project submissions. The recipients for 2024 are:
Embry-Riddle Aeronautical University (Compliance Innovations),
Post University (Licensure Programs),
Rio Salado College (Compliance Innovations)
Southern New Hampshire University (Location),
The University of Kentucky (Compliance Innovations and Licensure Programs), and
University of Nevada, Las Vegas (Location).
Noted below are additional details about each institution and their respective projects.
Winner: Embry-Riddle Aeronautical University (Daytona Beach, Florida)
Category: Compliance Innovations – Project Title: Creating Efficiencies and Ensuring Effectiveness through a SharePoint-based Change Management Process
(The Embry-Riddle Aeronautical University team-left to right): Ashley Toews, Nicole Wallace, Kelly Austin, John Watret, Will Miller, Katelyn Nelson, Danielle Farris, Will Miller, and Katelyn Nelson.
SAN is proud to announce that Embry-Riddle Aeronautical University (ERAU), a leader in aviation and aerospace educational programs, has won the 2024 SANsational Award in the category of Compliance Innovations.
ERAU, with campuses in Daytona Beach, Florida. It has residential campuses in Daytona Beach, Florida, and Prescott, Arizona, and offers online and face-to-face instruction through a network of 128 locations (representing 28 states, 8 countries, and 1 U.S. territory). ERAU’s mission is to prepare students for careers and leadership roles in business, government agencies, and the military by teaching the science, practice, and business of aviation and aerospace. ERAU offers greater than 70 baccalaureate, graduate, and Ph.D. degree programs, including majors in applied science, aviation, business, computers and technology, engineering, space, security, intelligence, and safety.
The impetus for ERAU’s winning project stemmed from the sheer scale and complexity of its operations. ERAU must often track and implement a variety of changes across the institution, including the establishment or closure of sites, program updates, site relocations, and name changes.
Before implementing the new process, managing these changes involved holding hour-long virtual meetings for each change, with up to 60 individuals from various departments within the institution. On average, 25-30 attendees would attend each meeting, resulting in a cost of approximately $1500 per meeting. During these sessions, attendees would provide input on a checklist of necessary items, often speaking for about 2 minutes each before listening to the remainder of the discussion. This method was not only costly but also time-consuming and inefficient.
In response to these challenges, ERAU transitioned to implementing a SharePoint-based checklist and tracking system that now allows stakeholders to provide their necessary changes/information in written form, which is then transparently shared with all other stakeholders. The benefits of this new approach include increased efficiency, cost savings, improved oversight, and enhanced satisfaction. This SharePoint-based system has transformed the management of ERAU’s complex scope of locations and programs. The process is now more efficient and effective and includes clear and transparent communications with all stakeholders.
Winner: Post University (Waterbury, Connecticut)
Category: Licensure Programs – Project Title: Maintaining Databases in Support of Personalized Student Licensure Advising.
Post University, a private institution founded in 1890, is located in Waterbury, Connecticut. It is known for its focus on career-oriented education. Post University offers a range of undergraduate and graduate programs, including degrees in business criminal justice, healthcare, and education.
Members of the Post University team from left to right Shawn Fields, [Jana Walser-Smith (State Authorization Network)], Melissa Pilloise, Christine Adamczyk, and Bryana Torres-Martinez.
The Post University team serves as a beacon for innovation, as the institution’s commitment to student support, progress, and success is the driving force for this team’s dedication. The Distance Education Compliance professionals at Post University embody the university’s mission of “Post Makes it Personal®”. The team strives to meet the needs of their students by providing the knowledge, skills, and experiences necessary to become leaders in their respective fields.
For these reasons, SAN is proud to award Post University the 2024 SANsational Award for its groundbreaking approach to advising and providing necessary disclosures to its students. In an effort to provide personalized advising to any student interested in licensure, which includes one-on-one contact before, during, and after enrollment, Post University maintains spreadsheets of state requirements with almost 23,000 data points on them. Simpler versions of these sheets are provided for university associates outside of the Credentialing Team that present over 8,400 data points. Potential and enrolled students interested in licensure programs are tracked on spreadsheets shared with Admissions, Advising, and Academics.
There are six sheets containing between 8-73 categories of information. To keep costs down and lighten the training load for associates, both Microsoft Excel and Microsoft Teams are employed (it should be noted that these are programs the University already utilized). Because of these methods for maintaining accurate data, 1,740 potential students were efficiently outreached regarding licensure in 2023. The verification and maintenance of data, as well as all student advising, is managed by a team of only four associates. SAN salutes Post University for providing a model that facilitates personalized service and a commitment to student success!
Rio Salado College – Tempe, Arizona
Category: Location – Winning Project: College Compliance Calendar Tool: Free Accountability for Us All
The SAN team presented an award to the Rio Salado College (RSC) team for their project submission in the Location category. RSC, a public, not-for-profit, institution located in Tempe, AZ.
(Rio Salado College’s team from left to right) Janelle Elias, Kate Smith, [Cheryl Dowd, State Authorization Network], Ramsey Itani, Melissa Schrand, Karol Schmidt, and Zach Lewis.
RSC was established in 1978 as the “College Without Walls” and was created to serve non-traditional students and began offering fully online classes in 1996. Today, RSC offers more than 600 online classes and approximately 130 degree and certificate programs to learners throughout Arizona and throughout the United States. RSC is recognized nationally and prides itself in being an innovative leader in online learning by making education accessible, flexible, and affordable to meet the needs of today’s students.
RSC’s SANsational Award-winning project is rooted in the Office of Institutional Integrity and Compliance (IIC), a department that coordinates with various stakeholders across the college to ensure compliance with all regulatory triad (federal government, state government, accrediting bodies) mandates. Through collaboration with stakeholders, RSC developed a compliance calendar using a SharePoint list for the college to monitor and maintain compliance. However, over time, many realized that the calendar was not user-friendly, and user access was a challenging issue.
At issue was the fact that RSC needed to find a way to maintain institutional and staff accountability for their compliance actions while simultaneously creating a user-friendly system that a public 2-year community college with a limited budget and resources could utilize. Accordingly, the idea to create a Google version of the calendar was born, but with a unique twist.
Instead of users simply adding information into a basic spreadsheet, each user was provided with a unique dashboard of their compliance items which is linked to a main Google sheet calendar. Users delegated their access based on the items they were assigned. Only the specific/authenticated user could access their calendar dashboard (unless they delegated someone else to manage it for them). Automated emails are sent reminding the staff of their items due with an option to add a reminder to their work Google calendar. These items are then fed back to the master calendar once tasks are completed. The master calendar has a reporting feature that can send custom reports of items past due or pending to the leadership.
The RSC team reports that the new process saves time and effort and was created with $0 in incremental costs. Additionally, the project followed a structure of shared governance which increased transparency and promoted accountability for staff who now have ownership in completing compliance tasks annually.
University of Kentucky – Lexington, Kentucky
Category: Compliance Innovations – Winning Project: The Global Compliance Pilot Project the Evolution of Distance Education Global
The University of Kentucky pictured from left to right: Chris Thuringer, Ellen Gish, [Kathryn Kerensky, The State Authorization Network], Casey Jones, Miranda Hines, John Wiesendanger, and Ping Jiang.
Known as the state of Kentucky’s flagship, land-grant institution, the University of Kentucky (UK) exists to advance the Commonwealth. UK does this by preparing the next generation of leaders, placing students at the heart of everything they do. The UK is delighted that it is transforming the lives of Kentuckians through education, research, creative work, service, and health care. The institution also prides itself on being a catalyst for breakthroughs and a force for healing, a place where ingenuity unfolds.
It is in that spirit that the SAN team is proud to celebrate UK for its exceptional contribution to the field with its Compliance Innovations project. This award-winning project emerged as the COVID-19 pandemic transitioned many students to online learning and created new restrictions on distance education emerged across various countries.
Concerns arose related to educational authorization, national security, cybersecurity, tax obligations, and other legal requirements in each foreign market where online programs might be offered. In response, the university launched a pilot project and established the Distance Learning Global Compliance Research Group (GCRG), consisting of members from Distance Learning Compliance, IT Cybersecurity, University Financial Services, and the Office of Legal Counsel. With no pre-existing policies or best practices to draw from, the university developed innovative frameworks and workflows that have set industry precedents.
The GCRG also implemented a Customer Relationship Management (CRM) system to streamline research documentation and the approval process, while creating dashboards for both public and internal use. After a year of implementation, the outcomes of the pilot project generated new insights and significantly influenced UK’s strategy. By sharing knowledge and best practices, the UK aims to advance industry standards in global distance education compliance, foster collaboration, and ensure sustainable practices across the sector.
University of Kentucky – Lexington, Kentucky
Category: Licensure Programs – Winning Project: Certification Procedures Planning Project: Collaborating Across Campus for Effective Regulatory Implementation
(The UK team pictured from left to right) Miranda Hines, John Wiesendanger, Suzanne McGinnis, Chris Thuringer, Ping Jiang, Jonathan Blazejewski, [Kathryn Kerensky-The State Authorization Network], Zach Furr, Adam Bohland, and Amber Campbell.
At UK, the Distance Learning Compliance Team led a campus-wide compliance project, collaborating with Information Technology Services, Institutional Research, the Office of Undergraduate Admissions, the Graduate School, Professional Schools, Financial Aid, and managers of all licensure programs.
UK developed the “DE PPA (Department of Education Program Participation Agreement) Licensure” program inventory and implemented a triple-level compliance screening integrated into various application systems to ensure transparency and clarity for applicants. This screening process allows prospective students to verify their enrollment eligibility before applying and remitting an application fee, preventing unexpected enrollment restrictions, and safeguarding their educational journey. Additionally, the project facilitated an inventory of the university’s licensure programs, automated direct disclosures, and increased campus-wide awareness of compliance and data management for state authorization, global compliance, and licensure programs.
University of Nevada, Las Vegas Las Vegas, Nevada
Category: Location – Winning Project: Accuracy in Data Collection (ADC) for Out-of-State Learning Placements (OOSLP)
Founded in 1957, the University of Nevada, Las Vegas (UNLV) is a doctoral-degree-granting institution with approximately 31,000 students and over 3,600 faculty and staff. UNLV is proud to be a Minority Serving Institution (MSI) with Hispanic-Serving Institution (HSI) & Asian American and Native American Pacific Islander-Serving Institution (AANAPISI) designations as well, having EEO/AA/Title VI/Title IX/Section 504 designations.
(The UNLV team pictured from left to right): Kate Korgan, Skip Crooker, Bridgette Perreault, Rex Suba, [Cheryl Dowd, State Authorization Network], Leeann Fields, Javier Rodriguez, Carrie Trentham, Terina Caserto (NSHE & represents Nevada’s State Portal Entity), and Jennifer Swanson.
With more than 158,000 degrees conferred and over 140,000 alumni worldwide, UNLV is classified as an R1 research university by the Carnegie Classification of Institutions of Higher Education®.
Naturally, SAN is proud to have presented the 2024 SANsational Award to UNLV for their submission in the Location category. Their initiative, Accuracy in Data Collection (ADC) for Out-of-State Learning Placements (OOSLP), provides an innovative and comprehensive approach to tracking and documenting student location.
When responding to the mandatory reporting requirements from NC-SARA, (requirements began in Spring 2019), UNLV identified the need for an improved method of tracking out-of-state learning placements. To begin the process, the compliance team connected with all UNLV colleges and schools, educating them about learning placement activities and identifying courses with learning placement activities.
However, due to differences in organizational structures, the team found it challenging to create a universal tracking method that would work across all colleges and schools. Each college and school had to rely on its own system to track placements throughout the year, resulting in inconsistencies in reporting. For four years, the Office of Educational Compliance (OEC) requested annual reports from colleges and schools via a spreadsheet, which proved to be an antiquated and rudimentary approach that needed more consistency and accuracy.
Recognizing the need for improvement and the demand for reliable data, UNLV sought a better solution. It was concluded that the most accurate data on student locations was known by course instructors. To capture this data effectively, UNLV developed a system that prompts instructors at the end of each semester (during grade submissions), to indicate the state in which the student completed their learning placement activity.
Specifically, courses with learning placement activities are flagged in the system. Thus, UNLV developed an overlay in the grading module for these courses that prompts instructors to indicate the state where the student completed the learning placement activity. Only when this information is provided can instructors enter the student’s grade. This data is then stored in the registration system, allowing for efficient report generation when annual reports are due.
Multiple levels of administration and offices collaborated on this initiative, which took two years to implement. The process was facilitated with significant contributions from the Office of Information Technology.
Southern New Hampshire University, Manchester, New Hampshire
Category: Location – Winning Project: Identifying Student Location and Reporting Such Information
Southern New Hampshire University (SNHU) is a private, nonprofit, accredited institution, located on a 300-acred campus in Manchester, New Hampshire. SNHU serves more than 200,000 learners worldwide, making it one of the fastest- growing universities in the nation. Founded in 1932, the University has undergone a transformation from a school of accounting and secretarial science to an institution that now offers over 200 accredited programs. SNHU’s academic offerings include undergraduate, graduate, certificate, and doctoral-level degrees.
(The SNHU team pictured from left to right): Scott Barker, [Jana Walser-Smith, State Authorization Network], Evan Lowry, Ellery Ewing, and Michelle Berthiaume.
SNHU’s programming and support services are strategically designed to fit the needs of today’s learners and the ever-evolving workforce. SNHU is committed to ensuring that students are keeping pace with innovative technologies and professional requirements, while simultaneously offering learners an exceptional student experience featuring nationally recognized academic programs.
The SANsational Awards Committee was impressed with SNHU’s innovative process that identifies and reports students’ physical locations, ensuring compliance with state and federal regulations. The ability to do so is particularly crucial for students enrolled in distance education and licensure programs. The process is grounded in automated biannual pop-up notifications in the student portal, which require students to update their location. SNHU advisors are automatically notified when a student’s location changes, enabling them to provide guidance on state-specific licensure requirements. These initiatives help SNHU maintain accurate student records, support compliance, and enhance the student experience.
Learn more about the 2024 Winners!
The SAN team expresses our sincere congratulations and well-wishes to each of the SANsational Award Winners! We are proud of your accomplishments and are grateful for your willingness to share your ideas and processes with our member institutions and organizations! Please also know how much the SAN team enjoyed our visits to each of your campuses when presenting their SANsational award in person.
For additional details on these fascinating projects, visit the SANsational Awards webpage. There, you will find recorded presentations from each of our winners detailing their processes, challenges, and outcomes. The recorded presentations are also transcribed and are approximately 20 minutes long.
Please keep in mind that your team/project could be a SANsational Award winner! Mark your calendars for the 2025 award self-nominations process which will begin in the summer.
For more information about the activities, events, and resources provided by the State Authorization Network (SAN), please visit the SAN Website or contact the SAN team at san-info@wiche.edu.
The direction for regulations and guidance for digital and distance education shifted greatly with the recent election. As you may recall, the U.S. Department of Education (the Department) was planning to release sweeping regulatory changes on distance education, accreditation, state authorization reciprocity, and mandatory fees for books and materials. They also planned changes to guidance for “bundled services,” which affects online program management relationships.
You asked about the state of the outstanding regulations and guidance. We will give you our best insights in this blog post. A future post will explore what might be expected from the new administration…and beyond.
A Rule is a Rule Until It is No Longer Rule
The truism in that title seems obvious, but we often hear from people who think that promised change is wholesale and immediate. It is not.
Many Department regulations are currently in place and have been for years. A few examples include regular and substantive interaction, obligations to meet authorization and professional licensure requirements in other states, and student identity verification – which ensures that the distance student completing an assessment is the same one who registered for a course.
Existing Regulations or Guidance: Any existing regulations will remain in effect until they go through an official process to be changed. Similarly, guidance is amended or withdrawn formally by the agency providing the guidance. There are several pathways for the official change process for existing regulations. In the following section, we will highlight what those processes are. Meanwhile, we urge you to remain in compliance with existing regulations and guidance.
Proposed Regulations or Guidance: Any proposed regulations do not go into effect until they complete all of the statutorily mandated processes to be implemented. Currently, several regulations are midstream in the process and have not reached the far side of the river. We will highlight some of those of interest the WCET and SAN memberships.
Remember: Transition Takes Time
There is a little more than two months between the election and the inauguration. The leadership (sometimes several levels down) in each and every department of the federal government will change due to political appointments and then set plans, mesh with career staffers, and find its own way forward.
The incoming administration is much better prepared than they were in 2016. They are even seeking to undertake some “creative” solutions to quickly get their people in place (use “recess” appointments to dodge delays in Senate confirmations) and hasten the implementation of their agenda (replacing career staff). Speculation on possible nominees for Secretary of Education include several who would definitely shake the rafters.
On the other hand, the Trump team has not signed the agreements required to facilitate the transition and obtain necessary clearances. This could slow them down.
How Regulations and Guidance Can Change
With a shift in the party controlling the White House, there could be some changes to federal regulations. Institutions are responsible for compliance with federal regulations. Changes to regulations typically require revisions through the statutorily directed rulemaking process. However, as discussed below, a Congress aligned with the White House priorities may be able to overrule new federal regulations. Additionally, the courts can weigh in to interpret statutory authority and vacate regulations.
Federal regulations are developed by administrative agencies (i.e., U.S. Department of Education, U.S. Department of Justice, etc.) to implement statutes. Regulations have the same legal effect as statutes.
Federal Rulemaking
Federal regulations, such as those developed by the U.S. Department of Education (the Department) must follow the rulemaking process directed by the Federal Statute – the Administrative Procedure Act (APA), to ensure public notice and comment. Generally speaking, to change regulations, currently effective regulations and any regulations that are released as final must go through another rulemaking process to amend or eliminate the regulation. Typically, that process takes the Department 18-24 months from the notice of rulemaking to the final effective rule.
The Trump administration has no responsibility to continue the rulemaking process for any issues that were negotiated by a rulemaking committee (i.e., Winter 2024 rulemaking issues) but not released as final by the end of the Biden administration.
Congressional Review Act
The Congressional Review Act (CRA) is a federal law that acts as a deregulation shortcut allowing Congress to overturn recently finalized federal regulations. In a nutshell, this federal law allows Congress, by a simple majority vote of both chambers, the ability to overturn new federal regulations within 60 legislative days of when they were issued. Once a rule is overturned, the CRA prohibits the reissuing of a new rule that is substantially the same rule that was overturned. Rules released by the Biden administration post approximately August 1, meeting the 60 legislative days, could be considered ripe for repeal. This is of interest related to distance education regulations as there is the possibility that the regulations, if issued as final before the Biden administration leaves office, could be subject to the CRA.
Courts
Over the last few decades, many regulations have been challenged in court with regulations vacated or the implementation directed by court decisions. Regulations that are legally challenged have sometimes been subject to a court order to temporarily suspend enforcement pending a final court opinion. Recent regulations have been challenged with claims of lack of statutory authority, failure to follow the APA, and constitutional arguments. The court opinion is considered case law with the same force and effect of law as codified statutes and regulations.
Executive Orders
Given the history of the first Trump administration, executive orders may be used as an option to deregulate. An executive order could direct agencies to delay and review all new regulations to consider whether to revise or rescind through a new rulemaking. Executive orders can be overturned by legislative action of Congress. The Supreme Court can overturn an executive order if the order conflicts with the U.S. Constitution.
Guidance
Occasionally, guidance, which has no independent legal effect or force of law, is released by the administrative agency to provide the agency’s view of the statutes and regulations.
Guidance, often called a Dear Colleague Letter (DCL), is to be written in plain language and only intended to clarify existing requirements in statute and regulation. Guidance is developed and withdrawn by the agency in a relatively informal manner and is not required to follow the APA that ensures public notice and input. The Biden administration may issue guidance before leaving office. The next administration has no legal obligation to maintain the guidance and could choose to withdraw the guidance.
2024 Negotiated Rulemaking
During the winter of 2024, the Department of Education engaged in negotiated rulemaking. After soliciting public comment in 2023, the Department decided to negotiate rules for accreditation, distance education, attendance, reciprocity, state authorization, and Return to Title IV (including inclusive access), among other topics. After negotiations failed to reach consensus, except for the TRIO issue, the Department released proposed distance education regulations for public comment earlier this summer. The proposed regulations included:
Creation of a new “virtual” location,
Collection of additional data for distance education courses and students, and
Attendance taking for distance education courses.
Potential inclusive access, reciprocity, state authorization, and accreditation regulations that were not included in the summer NPRM (Notice of Proposed Rulemaking).
After the release of the NPRM and proposed regulations, the Department entered a 30-day public comment period. After the public comment period, the Department is required to respond to all public comments. The draft final regulations are then per Executive Order 12866 submitted to the Office of Management and Budget (OMB) for an Office of Information and Regulatory Affairs (OIRA) Review. At that point, the OIRA Review includes a required set of EO 12866 meetings to give the public one last opportunity to weigh in on the regulations. Once the draft final regulations complete the EO 12866 process, OIRA may provide guidance to the agency to revise the regulatory package prior to the Department releasing the regulations as final. If the Department releases the final regulations by November 1st, they can go into effect on July 1st of the following year. In the case of the distance education NPRM, the Department did not meet the November 1st deadline.
The Department could still move forward with the OMB/OIRA review and release the distance education related and TRIO regulations as final prior to the January inauguration. However, because the regulations would be finalized and released so close to the next Congressional term, they would be subject to the Congressional Review Act. Should Congress and the new Trump administration choose, they could strike down those regulations and the Department would be unable to bring them forward again. Because of this, it is highly unlikely that the Department will move forward with the distance education regulations, and they are, most likely, dead.
As for state authorization, accreditation, and inclusive access, these regulations are most certainly dead. The Department does not have time to release an NPRM and engage in the public comment and OMB/OIRA 12866 process. And because the incoming Republican administration is antagonistic towards anything that would limit reciprocity and inclusive access, it is highly unlikely that a Republican Department of Education would move these regulations forward.
Accessibility
The recent WCET Frontiers post, Meeting the Looming Web Accessibility Regulations: The Time to Start Was Yesterdayprovided nuance and direction for compliance with new U.S. Department of Justice regulations released in April 2024, that apply to all “state and local governments to make their websites and mobile applications accessible for people with disabilities.” These regulations affecting public institutions became effective in June 2024 with compliance dates in 2026 and 2027 depending on the size of the jurisdiction for which the public entity serves.
The legal authority to develop web accessibility regulations comes from the federal law, Americans with Disabilities Act (ADA), signed into law in 1990 by President George H.W. Bush. Title II of the ADA addresses state and local government entities. Part A protects disabled individuals from discrimination. New regulations revise the implementation of this Federal law by adding specific requirements for web accessibility to protect disabled individuals to ensure that web content is equally available.
It is unclear if the Trump administration will attempt to delay or revise these regulations. These regulations have been final and effective since June 2024. Given the subject matter of this regulation, one must consider that any action by the administration would likely be addressed by judicial or legislative interventions. Additionally, public institutions must be aware of the possibility of private lawsuits if they are not compliant by the appropriate date given the size of the jurisdiction they serve, if the rules are not subject to a delay.
Online Program Management and Third-Party Servicers Guidance
The Higher Education Act forbids institutions from paying contracted student recruiting services a fee per student that they attract. In 2011, the Department issued guidance allowing for a “bundled services exception.” Incentive compensation” was allowed in the cases where recruiting was included with other services, such as online program development and marketing. This led to the growth of the Online Program Management (OPM) industry and worries about abuse of this exemption.
In February 2023, the Department seemingly tried to address this issue by expanding the requirements for institutions using “Third-Party Servicers.” The expansion of this narrow category aimed at financial aid processing services to, seemingly, covering every institutional contract with an external entity caused an uproar. The Department paused implementation of the guidance and promised a replacement and/or holding negotiated rulemaking on the issue. The Department officially rescinded the 2023 Third Party Servicer guidance effective November 18, 2024. Despite the March 2023 Department announcement of Intent to Establish a Negotiated Rulemaking to include the third-party servicer issue, that issue has not taken any further steps in the rulemaking process.
There is a small possibility that the Department could update or rescind the 2011 guidance that created the exception. This has been expected for years. Even if they do, it might be amended again quickly by the incoming group.
In Conclusion
It is not wrong for you to feel a sense of whiplash as the rules (whether regulation or guidance) change back-and-forth as the party in power switches. Congress has been ineffectual in passing laws for years and the action has fallen to the federal agencies.
Much of what we have discussed over the last few years either will not happen or may go away. In 2016, we made the mistake of thinking that a Trump Administration might mean he would deregulate everything. That was not the case! Although, some of the names suggested as Secretary of Education, if selected, may be so caught up in culture wars that deregulating their pet issues or simply running the place might fall by the wayside.
What will happen? We will continue monitoring. Watch for a future Frontiers post.
A recent NWHeat webinar highlighted that public institutions must mobilize immediately (if not sooner) to meet the coming U.S. Department of Justice (DOJ) accessibility guidelines. Released in April 2024, the new regulation requires “state and local governments to make their websites and mobile applications accessible for people with disabilities.” These rules encompass all public colleges and universities.
The new requirements apply to all public entities, such as state and local governments, in all of their functions, including motor vehicle departments, libraries, police departments, and K-12 schools. Yes, all public colleges and universities are included as well. A parallel rule covering private colleges is under development and is due to be released later this year or early next year.
What Will Be Required?
All content and functions of your websites, mobile applications, and social media that you are using after the implementation deadline will need to meet the specific accessible standards. This encompasses everything online or on your apps. It will affect students, faculty, and staff. A few examples of what needs to be accessible include (but are not limited to):
all content of online courses,
digital content for in-person courses,
online payroll/timesheet forms for staff,
course registration,
library content and searches,
third-party tutoring services,
content from publishers,
housing applications,
educational software,
your social media entries, and
student-submitted content if others are expected to use or review it.
Pretty much everything that is online. There are a few exemptions, but they are very narrow and specific. The details are too involved for this post, but ADA.gov provides a helpful fact sheet.
What Accessibility Standard is Being Used?
From the DOJ press release announcing the rule: “The agency is adopting the technical standards of Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which requires 50 success criteria to make websites accessible. This includes converting pictures and documents so they can be read with assistive technology for individuals with vision loss and providing captions for live and prerecorded videos for individuals with hearing loss.”
What is the Deadline?
The deadline is determined by the population of the geographic area that your public entity serves. Note that for colleges, it is NOT your enrollment, but the number of people living in the state or district you serve. So, the official geographic region from which the institution draws its students. The compliance deadline is:
50,000 or more people: April 24, 2026,
Fewer than 50,000 people: April 24, 2027.
Only colleges that serve a small county or service district will qualify for the later date. Most colleges or universities have a statewide mandate or serve a city or county with 50,000 or more in population. One example highlighted was that of an online K-12 school with eight students enrolled but has a statewide service area. That school fits into the earlier date for large populations.
Why are They Doing This?
DOJ tried a voluntary approach to accessibility. It has not worked.
The new requirements ensure that all public entities have a known and standard set of accessibility requirements that they must meet.
Initially, the DOJ proposed several exemptions for institutions that would have allowed five days to remediate non-accessible issues found on public entity content or applications. Based on the public comments submitted, they instead decided to follow a universal design approach, much as has been done with physical spaces.
These requirements will help both those with and without disabilities. Much like physical facility requirements, such as corner curb cuts, larger bathroom stalls, and door-opening buttons can help everyone, the new standards will provide a more successful and inclusive experience for all.
How is This Enforced?
These regulations will primarily be enforced through lawsuits alleging non-compliance rather than through actions by the DOJ.
What are Some Tips for Next Steps?
Mobley provided some great advice on actions that institutions should be taking, and I have organized them into categories:
Make an overall plan.
Communicate that the path to compliance is the responsibility of everyone. The days of relying solely on “disability services” offices are over. There is too much to do.
Catalog all the places where your institution has web content, mobile apps, and social media. Make a list of content and vendors, as you will need to work with vendors.
Prioritize your efforts. You have limited resources and you need to start by addressing the places with the most impact. Address the web pages and apps with the most traffic. Determine if there are programs that attract more students with disabilities and prioritize content and applications used in those courses.
Develop a plan with tasks and timelines.
Start working with faculty now!
Educate faculty on the requirements, roles, and timelines.
Encourage faculty to look at their textbook options. Publishers will likely only make new versions of textbooks accessible. Many faculty will make textbook selections for the next academic year in the spring, so work with them now.
Start making new content in courses accessible from the start. That will mean less content to remediate later.
Be prepared to answer questions or objections from faculty. For example, to objections regarding “academic freedom,” frame the discussion around that accessibility is not only a legal requirement, but an opportunity to reach more students.
Start working with administrators now!
Educate administrators on the requirements, roles, and timelines.
Post notices for students about where they can get help with their accessibility challenges. Do not lean solely on the disability office.
If you have a request or complaint, address the specific issue (which may take weeks or months to resolve), but also find a solution for the person who raised the complaint, even if it may not be the permanent solution eventually put into place.
Examine all contracts in regard to the date that your institution needs to be in compliance (April 2026 or 2027). What is currently out for procurement? What contracts will be due for renewal. What contracts automatically renew?
Work with your vendors and contracted entities.
Communicate with them about how they will address your compliance needs.
Collaborating with other institutions or with membership groups often gives the college or university greater leverage in requesting accessibility features than working alone.
Like in all big journeys, successfully meeting these new standards will be accomplished a step at a time. Make a plan. The sooner you start, the easier the path will be.
Of course, the results of the election that was held since this webinar might have an impact on the future of this regulation. It will take quite a while for clarity to emerge on that issue. Meanwhile, we hope that you continue to support students with disabilities as much as you can.
This post was written by Russ Poulin, WCET and published in collaboration with NWHeat.
Resources
Due to Office of Civil Rights’ policies, the webinar was not recorded nor were the slides shared. Resources that were shared during the webinar are shared on the NWHeat website.
WCET and State Authorization Network (SAN) members have access to a members-only brief on these regulations: Access for All: New Accessibility Rules for Public Entities. Links to the document for: WCET members and for SAN members.
View from the conference hotel. Yes, it was foggy. Every morning.
Welcome to Frontiers! It’s getting colder on my side of the country, so I’m fondly thinking of our week in CA earlier this month.
Today, I’m sending you all the sandy, sunshine-filled highlights from WCET’s 36th Annual Meeting! Picture this: Nearly 300 digital learning enthusiasts swapping tales of AI adventures, chatting about accessibility, and finding the best culinary options Long Beach offers! From impromptu beachside brainstorms to deep dives into student success, this year’s event was a fun ride through the latest in higher ed digital learning policy and practice. So, grab your shades and settle in for a postcard-perfect recap of WCET 2024!
The most trending topics presented this year included:
Generative AI in Higher Education – Discussing ethical use, inclusion, and innovative applications of AI in digital learning.
Student Success and Digital Equity – Strategies for fostering first-year persistence, student affordability, and support for underrepresented learners. Our fantastic keynote, Marina Aminy, Executive Director of the California Virtual Campus, highlighted students’ lived experiences. Her unique perspective, gathered from her own higher education journey, plus those as a parent to a college student, made the message about the challenges students face and what we can do to support them genuine and practical. I especially appreciated the discussion on transcripts and the vast and unnecessary barrier this is to student success. Thank you, Marina!
Compliance and Regulation Updates – New DOJ accessibility guidelines, federal policy updates, and implications for online education.
Digital Transformation – Exploring effective strategies for LMS selection, online quality frameworks, and digital fluency.
Exciting Moments
Luke Dowden and Russ Poulin accept the Richard Jonsen/ Mollie McGill Award
This year, we shined a well-deserved spotlight on Russ Poulin, our fearless Executive Director, who will retire at the end of the year.
From surprise awards to fun treats and even more memorable photo ops, we cherished the opportunity to celebrate Russ and express our gratitude for his remarkable dedication to the higher education community.
We also honored this year’s WCET Award Recipients at the annual WCET Awards Lunch and Program.
We’re proud to showcase these outstanding individuals, initiatives, and institutions that are driving innovation, advancing student success, and shaping the future of digital learning in higher education.
This year’s Annual Meeting attendees joined us from around the country to explore the latest advancements in digital learning, navigate the evolving regulatory landscape, and network with the outstanding WCET community. Here is what some of our attendees had to say about this year’s conference:
“The informal networking that occurs throughout the meeting is one of the most valuable aspects of the annual meeting but there were great sessions right through to the end. I liked the different tracks so I could easily see the sessions that were most relevant for me.”
“I am beyond thankful for the great work of the WCET team in putting together this annual meeting. This was a great opportunity to learn, network, and gather valuable input and resources. The layout of the event was great in terms of sessions, organization, flow, and scheduling. The whole WCET team was welcoming. The mobile app was very user-friendly and I am glad that it had the sessions, time, location, and all the relevant information all in one place. The food was great. All the sessions added value to my experience. I got to network in a way that was meaningful and valuable. I met great people and made connections. I would recommend this event to others. I joined last year and this year was my second time attending. This has become my go-to annual meeting and has helped improve my professional development. I always learn something new and get to take home valuable resources.”
“I really liked the opening keynote speaker – she was thought-provoking and engaging.”
“#freethetranscript”
“The people! Everyone is so friendly, helpful and impressive with their work!!!”
“The people. I met so many great people.”
“Being in community with practitioners. I just love the community vibe of the annual meeting. No other conference achieved the “closer conversations” and feeling of closeness that I experienced at WCET.”
We “heard” your suggestions for improvements too! Here are some of the improvements you requested:
More snacks, coffee, and black tea!
Tracks for specific levels of expertise and role types.
Larger rooms for the more popular topics.
Re-structure the expert library and keep it for next year.
We are already using your feedback to help us plan and prepare for WCET 2025!
Actionable Strategies
While I didn’t get to attend as many breakout sessions as I wanted, I’ve heard many compliments for our speakers this year! Kudos! However, I gathered some ideas that resonated with me as essential steps to consider now that we are all back home.
Create an AI Ethics Statement aligned with your institution’s mission, vision, and values. The statement should consider transparency, justice, fairness, equity, non-maleficence, responsibility and accountability, privacy, and accessibility.
#FreetheTranscript!
Digital learning practices that embrace culturally responsive teaching and prioritize humanizing the student experience can directly influence student success. When we meet students’ needs beyond the classroom, we positively impact their in-class performance. Digital learning empowers faculty to tailor instruction to diverse needs, foster collaborative learning, and provide more accessible student support.
Updates to Title II of the ADA establish requirements for digital, web, and application accessibility for public entities. These entities must comply with WCAG 2.1 Level AA standards for services, programs, and activities. If you have not already, it’s time to plan for compliance with these requirements.
Continuing the Conversation
At the end of the conference, Russ had us all fill out some WCET postcards with our takeaways from the meeting. WCET will mail those out to those who completed one so you can remind yourself about what you learned and what next steps you will take. As always, we want you to have the necessary resources to take those actionable steps toward student success and digital learning improvement. Here are some of our recommendations:
Caring for the Whole Student – report from Every Learner Everywhere on how faculty and staff can address student mental health.
WCET Policy Resources—This page includes all of our policy work, including resources on Regular and Substantive Interaction, State Authorization, Professional Licensure, Digital Accessibility, and more.
WCET Frontiers – my shameless plug to check out other blogs here on Frontiers, plus subscribe to receive notifications of new posts. We’ve got articles from our talented staff, plus guest posts from outstanding practitioners and experts in digital learning and higher education.
So, what did you write on your postcard? Or what would you have written?
We’re excited to hear from you about the steps you will take to address some of these topics. Share your ideas and questions with us! Comment on this post on WCET’s LinkedIn page, and WCET members can share their thoughts and questions in the DISCUSS community on MIX – the online community platform and email discussion group for WCET and SAN.
Finally, pencil in WCET 2025 now (or, really, just add it to your online calendar)! Next year’s event in Denver, CO, will be held October 21 – 23, 2025, and bookended by the annual SAN Coordinator Meeting and Gathering and the Annual Summit for Women in eLearning (ASWE).
Save the dates and keep a look out for more information coming soon – like the call for proposals, which opens in March.
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![Members of the Post University team from left to right Shawn Fields, [Jana Walser-Smith (State Authorization Network)], Melissa Pilloise, Christine Adamczyk, and Bryana Torres-Martinez.](/wp-content/uploads/sites/11/2024/11/post.jpg)
![(Rio Salado College’s team from left to right) Janelle Elias, Kate Smith, [Cheryl Dowd, State Authorization Network], Ramsey Itani, Melissa Schrand, Karol Schmidt, and Zach Lewis.](/wp-content/uploads/sites/11/2024/11/rio.jpg)
![The University of Kentucky pictured from left to right: Chris Thuringer, Ellen Gish, [Kathryn Kerensky, The State Authorization Network], Casey Jones, Miranda Hines, John Wiesendanger, and Ping Jiang.](/wp-content/uploads/sites/11/2024/11/kentucky-1024x671.jpg)
![(The UK team pictured from left to right) Miranda Hines, John Wiesendanger, Suzanne McGinnis, Chris Thuringer, Ping Jiang, Jonathan Blazejewski, [Kathryn Kerensky-The State Authorization Network], Zach Furr, Adam Bohland, and Amber Campbell.](/wp-content/uploads/sites/11/2024/11/ken2.jpg)
![(The UNLV team pictured from left to right): Kate Korgan, Skip Crooker, Bridgette Perreault, Rex Suba, [Cheryl Dowd, State Authorization Network], Leeann Fields, Javier Rodriguez, Carrie Trentham, Terina Caserto (NSHE & represents Nevada's State Portal Entity), and Jennifer Swanson.](/wp-content/uploads/sites/11/2024/11/nev.jpg)
![(The SNHU team pictured from left to right): Scott Barker, [Jana Walser-Smith, State Authorization Network], Evan Lowry, Ellery Ewing, and Michelle Berthiaume.](/wp-content/uploads/sites/11/2024/11/s-n-h.jpg)
