Hello everyone! I hope your October is off to a delightul start and you’ve been able to stay healthy!

I want to take a an opportunity to talk about the other side of the state authorization coin - Do you know where your faculty are located?

The location of college and university faculty & staff is likely to become a very very big issue in the coming year, post-pandemic, as more and more we realize the potential mobility of the workforce in higher educaton. What do I mean? Well let's take me for example. I rarely, if ever, see students and most of my work consists of meetngs on compliance (or these days creating a common curriculum) or creating, finding, and editing documentation on compliance. Other than providing the office with my sparkling personality, wit, and humor, do I need to be physically at the university/office or even in Colorado*?

But what we may not have taken in to consideration is what happens when the location of the faculty & staff changes? What happens with things like state taxes? What about those who are working in professional education like Nursing? Those of you who work with some of the out-of-state placements for students may know that many institutions outside of CO won't place students here for internships etc. b/c of Colorado's Worker's Compensation laws and requirements. Are there states where the universities may be required to hold workers compensation insurance if we have faculty/instructors who are living and teaching online from there? In fact, some state tax rules have already changed. As WCET noted in. their great piece on the multi-state workforce,

Five states, Connecticut, Delaware, Nebraska, New York, and Pennsylvania tax employees where their office is located, even if that office is outside of the employer’s state. This is often referred to as a “convenience” or income sourcing rule. In many of these states, the employee may be denied a tax credit or deduction from taxes paid to another state, potentially resulting in double taxation. Generally, if the employee may only carry out their work in that specific state location, they may be exempt from this rule. Specific conditions by state and the employee’s situation will apply.

I highly recommend you take the time to review the article and share with colleagues (including legal and those in HR positions) as we all start to look ahead at the changing landscape of our workforce and increase our digital footprint outside of Colorado.

Looking ahead to next month - The State Authorization Network (SAN) Annual Coordinator Meeting will be held on November 30th. It's an online event again this year (b/c pandemic) and will feature a couple of optional pre-meeting sessions (one for new coordinators or new to SAN as a whole, and one for some informal networking) from 11-11:45am before the 90 minute Coordinator meeting (12pm -1:30pm). This year's meeting will focus on some of the emerging compliance issues (like the taxation issue noted above as well as regulations coming out of the VA, and data privacy) and a selection of Table Talks - round table discussions among members and some outside experts on specific topics or issues. I'm really excited to be working with WCET-SAN on bringing in a couple of folks from the Department of Education's Institutional Review office (Philadelphia branch) to talk to us about the Tidle IV Program Review Audits and how our work factors in to what our colleagues in Financial Aid have to produce as evidence of compliance with 668.43 (institutional/consumer information including professional licensure programs) and 600.9 (state authorization), how we can assist them in the event of an audit as well as what and how they will be reviewing our institutions in terms of compliance with new regulations/definitions on distance education (600.2). While compliance with these regulations are also reviewed at the time of accreditation reviews and are affirmed by CDHE when we renew with NC-SARA participation, the Ed and their program auditors do look at them as well, but of course, from a *slightly* different angle. As soon as registration opens for this meeting I'll be sure to let you know!

Have a great rest of your Thursday and an excellent weekend!

Erika

* Don’t worry Rob, I have no plans to leave CO, no mader how much I miss a good fresh east coast bagel.

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