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The SHEEO State Authorization Survey: Development - Data Collection - Analysis

April 30, 2012 Sharmila Basu Conger State Higher Education Executive Officers (SHEEO) Marianne Boeke National Center for Higher Education Management Systems (NCHEMS). The SHEEO State Authorization Survey: Development - Data Collection - Analysis. Webinar Agenda. Background to the Inventory

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The SHEEO State Authorization Survey: Development - Data Collection - Analysis

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  1. April 30, 2012 Sharmila Basu Conger State Higher Education Executive Officers (SHEEO) Marianne Boeke National Center for Higher Education Management Systems (NCHEMS)

    The SHEEO State Authorization Survey:Development - Data Collection - Analysis

  2. Webinar Agenda Background to the Inventory SHEEO Survey Development and Data Collection Results and Website Contents Analysis of Collected Data Discussion with Participants
  3. Background to the Inventory:Federal Regulations October 29, 2010 USDOE's 'state authorization' regulations issued March/April 2011 Dear Colleague letters released July 12, 2011 US District Court for DC strikes down the distance education portion of the regulations; USDOE appeals ruling. Summer 2012 Ruling on USDOE appeal expected
  4. Background to the Inventory:Other Surveys Why the State Higher Education Executive Officers (SHEEO)? Other surveys: WCET Starter List Dow Lohnes President’s Forum Eduventures State Efforts (Florida & Massachusetts)
  5. SHEEO Survey: Methodology Timeline: April 2011 – September 2011 SHEEO contracted with NCHEMS to develop, administer, and collect responses to a State Authorization Survey Survey Development Reviewed other state authorization surveys Created a rubric of questions and agency contacts Worked with an advisory board to create the final survey Survey Administration Unit of analysis is agency - NOT state. Sent inventory to all agency contacts in July 2011 Requested verification and completion of data Response Collection and Creation of Agency Reports
  6. SHEEO Survey: Contents, Part 1 Questions 1-6 (of 12): Agency and contact information Types of educational providers authorized Accreditation Requirements Program Approval Requirements Exemptions Authorization of distance education Physical presence policy – common triggers Application process
  7. SHEEO Survey: Contents, Part 2 Questions 6-12 (of 12): Fees associated with authorization Interstate reciprocity Consumer protection and student complaints Enforcement Legislative or regulatory changes Anything else about the authorization process in your state that we should know about?
  8. SHEEO Survey: Participation 78 state agencies 50 U.S. States – 69 agencies 9 U.S. Territories – 9 agencies As of December 2011 – 64 completed, 14 missing 10 U.S. State agencies 4 U.S. Territory agencies All completed surveys/contact information available on the SHEEO website – including contact information for the missing agencies, thanks to Dow Lohnes!
  9. Survey Participation – Missing States Survey missing, 1 agency Surveys missing, 2 agencies Plus: Commonwealth of Northern Mariana Islands Federated States of Micronesia Guam Republic of the Marshall Islands
  10. SHEEO Survey: Limitations Inventory was long (9 pages). State agencies were overwhelmed. Timing… July 2011. Middle of summer Federal Regulations had just been vacated. It is important to note that it is, and has always been, state law. SHEEO agencies Only 70% of states have their SHEEO agency as one of the authorizing bodies for the state Less than 50% of total authorizing bodies are SHEEO agencies
  11. SHEEO Agencies vs. State Authorization Agencies, in the U.S. States and D.C.
  12. SHEEO Survey: Project Results Available on SHEEO State Authorization website: http://www.sheeo.org/stateauth/stateauth-home.htm Compendium of state laws and regulatory practices Contact list of state regulators Complaint process and links list Fees structure summary Analysis of selected data
  13. Project Results: Contact List of State Regulators 78 total State Authorization Agencies identified 69 agencies in 50 U.S. States 9 agencies in 9 U.S. Territories (includes D.C.) Distribution of agencies in U.S. States + D.C.:
  14. States with More than One Agency 2 Agencies 3 Agencies
  15. Project Results: Student Complaint Processes 54 of 78 state agencies (70%) reported having a process in place for handling student complaints about postsecondary institutions or programs. 12 of the 54 agencies with processes (22%) stated that this complaint process even extends to institutions not authorized by the agency, if those institutions enroll residents of the state. If your agency has no formal process for handling complaints related to postsecondary institutions, what state agency would handle a complaint?
  16. Project Results: Fees Structure Summary All state agencies listed their fee structure on the survey, or provided a web link to their fee structure. The fee for authorization varies from $0 to $10,000+. 4 state agencies do not charge any fee for authorization. 7 agencies require a fee for a waiver/exemption. There can be other fees involved: Site Visit Surety Bond Tuition Recovery Fund
  17. Fees Structure – No Fee for Authorization No fee for authorization
  18. Fees Structure – Fee for Waiver/Exemption 2 Plus: Puerto Rico Fee for waiver/exemption
  19. Analysis of Collected Data: U.S. States and DC SCOPE of authorization agencies ACCREDITATION requirements for authorization Separate PROGRAM approval requirements Allowable EXEMPTIONS to authorization Regulation of DISTANCE EDUCATION providers Common PHYSICAL PRESENCE triggers
  20. Scope of Authorization
  21. Institution Types Authorized
  22. Accreditation Requirements
  23. Types of Accreditation Required
  24. Separate Agency Required for Program Approval?
  25. If program approval required, in what areas?
  26. Exemptions
  27. 8 States with agencies that DO NOT allow ANY exemptions or waivers, for ANY reason
  28. Which Institution Types are Exempt?
  29. Distance Education
  30. 4 States with agencies that require an exemption for a PURELY ONLINE program - even with NO physical presence
  31. September 2011:12 States with agencies requiring authorization without regard to physical presence 2
  32. April 2012:8 States with agencies requiring authorization without regard to physical presence 2
  33. Physical Presence Triggers
  34. Getting the Process Started, Part 1 10 Steps you can take to begin the state authorization process: Select the right person to lead Review your enrollment history - do you know where your students are? Develop relationships across your institution Engage and inform institutional leaders Research state agency regulations
  35. Getting the Process Started, Part 2 Develop a relationship with regulators Determine where you will apply Apply! Determine post-approval steps and timelines Document what you do Sharyl Thompson, Vice President of Regulatory Affairs and Compliance, American College of Education Russell Poulin, Deputy Director, WCET – WICHE Cooperative for Educational Technologies
  36. Include in email correspondence: Number of students in that state Types of programs offered – degree, non-degree, or both? Physical Presence triggers in that state: Instruction – Externships, clinical partnerships, seminars Recruiting – Agents in state, frequency of contact w/ students Property – Equipment (computers) or Instructional Site Employment – Faculty members, mentors, supervisors 3rd Party Contracts – Proctored Exams, Student Services Advertising – National Media or Local Media (targeted) Complete contactinformation, so they can contact YOU
  37. Conclusions & Next Steps There is huge variation in practice regarding how state agencies authorize institutions. What about program authorization? SHEEO is working on: Updating all agency surveys (twice per year) Continued analysis of survey data Monitoring the Federal Regulations More study and discussion are warranted
  38. Conclusions & Next Steps Quality Assurance is more than Authorization A number of groups are engaged in the work: Institutional Organizations – APLU, etc. Higher Education Agencies – SHEEO All other Authorization Agencies State Governments – CSG Regional Associations – WICHE, SREB, etc. Distance Education – President’s Forum, WCET Accreditors – CHEA, DETC, etc. Wide variety of scope, reach, interest, and authority
  39. Conclusions & Next Steps State Authorization “Commission” Development in progress Seeking to involve all relevant parties Easing Administrative Burden Shared understanding of need Discussions in progress Final product yet to be determined Need ALL at the table for success!
  40. Thank you! For more information, please contact: Sharmila Conger: sharmila@sheeo.org Marianne Boeke: marianne@nchems.org For more information about state authorization, please visit the SHEEO web site: www.sheeo.org/stateauth/stateauth-home.htm
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