Hello everyone!

I know it's not for a few months but don't forget to mark your calendars: the 2022 timeframe to report Fall 2021 exclusively distance education enrollments and calendar year 2021 out-of-state learning placements (OOSLPs) is May 15, 2022 through June 15, 2022.

You can register for NC-SARA's Data Reporting Webinar - March 10, 2022 11:30-1pm: This webinar will help SARA-participating institutions understand the guidelines for data reporting to NC-SARA. The presentation will review the 2022 Data Reporting Handbook in general, the guidelines for reporting specifically, and leave time for questions and discussion. This webinar is free and open to all - but registration is required if you want to join in.

NC-SARA's Data Reporting Handbook for Institutions (2022) is coming soon, but in the meantime, here is some important information that the folks at NC-SARA have shared now:

• Reporting data from Branch Campuses: It is important to note that Branch Campus reporting was originally planned to be mandatory for data reporting in 2022. However, due to a desire to ensure that the data reporting guidelines and examples for branch campus reporting are clear, and to give institutional staff more time to set up systems to collect and report these data, NC-SARA has postponed this requirement for another year.
• There are no changes to reporting for exclusively distance education enrollments.
• There are no changes to the criteria for reporting out-of-state-learning placements.

For questions about NC-SARA’s Annual Data Reporting, feel free to ask me or you can contact NC-SARA directly at data@nc-sara.org.

It's Negotiated Rule Making Season at the Department of Education and just when we thought thinks like State Authorization and/or Professional Licensure would be off the table this time, it looks like we may be wrong.

The ED is proposing that the professional licensure notification requirement (found in 668.43) be removed and instead a MUCH MORE STRINGENT requirement relating to professional licensure would be added to 668.14 (Program Participation Agreement) that would require the institution to ensure that it meets educational (and perhaps other) requirements for a student to obtain licensure in a state. In short, to give federal financial aid to a student, your institution must be able to show that your program meets the state's professional licensure requirements.

So for example - if I had a student living in Nebraska who wanted to come to Boulder to study Geology, b/c we haven't determined/don't meet the NE educational provisions for licensure in Geology, we wouldn't be able to allow that student to access federal aid (Title IV) for that program should they wish to ahend.

Seriously.

This was a huge shock and surprise to all of us. And while a lot of of us have a high capacity for work what would be required of us if this comes to pass would be absolutely unmanageable - even for those with a small number of licensure programs. The capacity necessary to not only ensure we're delivering the required education but the faculty necessary to carry this out, the financial aid office needs to have better connections to academics and folks like us... yikes is the nicest word I can use here.

Now. This and the other things in Neg Reg this year are still in the general public comment phase, but the fact that there is apparently someone(s) in that mix that still feel that students somehow continue to not get the information they need about these programs is a signal - in my opinion - that there's a misunderstanding about what we're all doing and/or this is aimed at a very particular type & sect of higher education (read: the proprietaries) without the understanding that we would all have to respond and comply, regardless of sector. Not to mention they fail to understand that the states and the licensing orgs in the states make the rules and they are all different and change.

Is there anything we can do right now? No. Like I said, this is still in the public comment phase - which if you'd like to listen in and participate in Session 2, February 14-18th, you can sign up here. Aler this comes the locking the negotiators in the room and making them fight it all out before a dral of the new rules are published. There are multiple opportunities for people to be told this is a bad bad bad idea that will really limit interstate education not to mention limit school choice, increase our costs, burden to licensing boards, and ignores a mobile and digital society.

The folks over at WCET have done a couple blog posts in Frontiers on the Neg Reg (including the return of Gainful Employment) and other upcoming possible policy changes this year that I cannot recommend enough-

• 2022 Digital Learning Policy Preview, Part 1: U.S. Department of Education Negotiated Rulemaking
• 2022 Digital Learning Policy Preview, Part 2: Federal and State Rules

I promise for March I'll have something more fun, like "when is a field trip no longer a field trip - out of state education considerations," but until then as always if you have any questions, please don't hesitate to reach out!

Sincerely,
Erika

Erika G. Swain
Interim Assistant Director for State Authorization
Office of Academic Affairs
University of Colorado System
e: swaine@cu.edu
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Assistant Director for Compliance and Authorization
Office of Data Analytics | Office of Institutional Research
University of Colorado Boulder
e: Erika.Swain@colorado.edu
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o: (303) 735-8184
c: (518) 637-9785

“Today I will be a Bulgarian Minister of Education,” Bokonon tells us. “Tomorrow I will be Helen of Troy.” - Vonnegut, Cat’s Cradle