Happy New Year!

I hope you all had an enjoyable and restful break/holiday! I got Covid for Christmas so that was fun #firsttimersclub

All this cold weather has me thinking of an island vacation so what a better time to look at some updates and changes in authorization with some of the islands and the various nations and territories.

• Adding American Samoa to disclosures ‐ American Samoa, the small unincorporated US territory in the Pacific, and the students who may be receiving their education from your campus online are to receive all necessary disclosures relating to professional licensure programs. The SIS has been updated to accommodate your campuses/programs determinations. Make sure you also coordinate with the folks in admissions as they are communicating with the prospective students and those disclosures are required as well.
• Palau joined WICHE! What does that mean for us? ‐ Hat tip to Rob Stubbs for noting that he small island nation of Palau has joined WICHE in the last year, which is fantastic as it allow(s) students from those areas to enroll in undergraduate, graduate, and professional programs elsewhere in the West and save on tuition costs. However, it's important to note that for the purposes of state authorization, we are to continue to treat Palau as a foreign country as they became an independent republic in 1981. Their membership in WICHE only pertains to the cost
  of education, not the delivery of the education through alternative modalities to students located on the island. There's been no word as to whether or not we would need to register in the Palau to deliver education there.
• The same cannot be said, however for the Bahamas. Do you know if you have any students located in the Bahamas? I hope you don't. The Bahamas require US institutions to apply for authorization from their National Accreditation and Equivalency Council for approval to deliver education to students located on their islands. As of today, only 14 US institutions have gained approval ‐ none of which are any of the CU campuses. Should you have students enrolled in any of your online programs (traditional distance education or Coursera based) this should be acted upon immediately.

Enough with these warm weather fantasies! Let's turn our attention north, to Canada (aka, America's Hat):

I know that most of you are thinking, hey Canada doesn't fall under state authorization and you're very right it doesn't. Buuuuuut ‐ is international authorization being handled on your campus? But whom? Have you coordinated with them at all since many of the rules and processes may be similar? Considering the growth that all three of our campuses are hoping for when it comes to "online" education, making sure that we are following all of the necessary requirements and regulations (and especially those of our closest neighbors) is a must.

First thing you need to know is that Canada does not have a unified agency overseeing higher education like we do. Education and the delivery of it is overseen by the individual Provinces and Canadian Territories, and what is required in one is likely going to be different in another. For example, after a quick conversation with a lovely woman in SK and the SK Higher Education Quality Assurance Board I'm pretty sure Boulder will not need to seek additional authorization there (we're public and have no physical presence in SK), but I still want to take a closer look to be sure. Ontario however.... well, they hung up on me after briskly telling me to send them a letter.

The folks at WCET‐SAN have put together some amazing documentation to help us and our colleagues out with this work. I've attached their Guide to Higher Education Regulation in Canada to this email and really recommend you take some time to review it. Remember, if we're conducting business in a province (i.e., delivering education, recruiting, advertising ‐ depends on their definition) we may also be subject to their tax laws. Please share this with the folks on your campus that are working to enroll students in your online courses and programs (including certificates and MOOCs offered on Coursera ‐ again, they cannot represent the university or act on our behalf in these areas). I've also attached a slide deck from a friend of mine from the University of Arkansas. Cleston, who has recently accepted a position at Dartmouth, has done extensive work on international compliance (especially with UA's Nursing departments) and has put together a very easy to understand and use research process and list of stakeholders to be included in this work. Like the work we have done on state authorization, this is not easy work, but necessary to remain compliant and competitive in today's higher education landscape.

And finally ‐ campuses should have received their notification of SARA renewal along with the invoice by now. Don't forget to contact Kelly Maden (kelly.maden@cu.edu) at System with a copy of your invoice and the speed type used to pay the invoice and your campus will be reimbursed for the SARA fees by System. If your renewal hasn't been processed yet and your campus owes the State Portal Entity additional information, please act on that immediately.

One more thing ‐ you may have heard that the Biden Administration announced the topics for the upcoming sessions of Negotiated Rule Making slated for this spring. On that list was accreditation, state authorization, third‐party servicers, ATB, gainful employment, and distance education among other things. These areas are interrelated and regardless of what comes out will impact our roles and institutions. I would also note you should keep an eye on some of the discussions that will happen around accessibility, accountability, and the web ‐ these regulations will directly affect public institutions and education offered online. Title II isn't necessarily an area I excel in, but I'll keep you posted as information there develops.

Have an excellent first full weekend of the new year my friends, and as always if you have any questions please never hesitate to reach out!

Sincerely,
Erika

Erika G. Swain
Associate 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) 637‐978