Current Regulatory Challenges Presented by International Student Participation in Non-traditional Programs and Recommendations for Change

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1 Current Regulatory Challenges Presented by International Student Participation in Non-traditional Programs and Recommendations for Change The NAFSA Task Force on Non-traditional Programs October 2012 These findings were submitted to NAFSA by the Non-traditional Programs Task Force. NAFSA staff will use them as the basis for a white paper to be submitted to the Department of Homeland Security and in liaison with the agency.

2 Members of the Task Force David L. Di Maria (Chair) Associate Director, Office of Global Education Kent State University Donald R. Back Director, Virginia Tech Language and Culture Institute Outreach and International Affairs Virginia Polytechnic Institute and State University Adria Baker, Ed.D. Associate Vice Provost for International Education Executive Director, Office of International Students & Scholars Rice University David Elwell Director, International Students and Scholars Office Brandeis University Mathelda Molina SEVIS Coordinator ELS Language Centers Norman J. Peterson, Ph.D. Vice Provost, International Education Montana State University Ali Soltanshahi International Student & Scholar Advisor Iowa State University of Science and Technology Rachael C. Weber International Student Adviser Oregon State University With assistance from the following NAFSA professionals: Michelle Kudrin Sheila Schulte Steve Springer Daniela Verma 2

3 Contents Current Regulatory Challenges Presented by International Student Participation in Non-traditional Programs and Recommendations for Change... 1 Members of the Task Force... 2 Contents... 3 Executive Summary... 4 Introduction... 5 Charge of the Task Force:... 8 Data Collection... 8 Results... 9 How current regulations limit the ability of institutions to offer non-traditional academic programs. 11 Miscommunication regarding the administration of non-traditional programs How campus leaders are preparing Recommendations Conclusion References Appendix A: Survey Questionnaire Appendix B: Survey Responses

4 Executive Summary Higher education programs in the United States and around the world are undergoing rapid and substantive change. For example, more than 6 million U.S. university students now take at least one of their classes each semester online. International programs of U.S. colleges and universities are changing rapidly as well, driven by technology and other factors, such as the dramatic expansion of dual-degree and joint-degree programs in partnership with institutions abroad, and the demand for short-term, non-degree educational programs. However, U.S. immigration policies regarding international educational programs and international students have not adapted to these major changes in educational programs. As a result, there is a growing problem, as U.S. colleges and universities try to offer leading edge international programs within an immigration policy environment that has not kept up with the times. In 2011, NAFSA: Association of International Educators formed a Task Force on Non- Traditional Programs to identify issues pertaining to non-traditional, yet increasingly common, methods of instruction and associated constraints by current federal regulations pertaining to non-immigrant students. Members of this Task Force represented a wide range of institutions and program providers. An internet survey was distributed to educators across the United States to collect feedback on the types of non-traditional programs in existence and the associated regulatory issues pertaining to non-immigration students. Finally, the Task Force facilitated an open meeting during the 2012 annual NAFSA conference in Houston, TX in an effort to expand on the quantitative findings of the survey. As a result of survey and open meeting, the Task Force identified types of programs affected and problems encountered as a result of current regulatory restrictions. In particular, 4

5 short-term programs (e.g., summer programs) and non-credit and non-degree programs proved most affected. The greatest issue reported by respondents was the appropriateness of the tourist visa for educational endeavors (e.g., educational tourism) as well as ambiguity associated with the applicability of current regulations and new trends in education. Introduction Globalization is having a profound effect on higher education. Governments around the world have responded by establishing new policies empowering educational institutions to succeed in an environment where education and economic competitiveness are intimately linked (U.S. Government Accountability Office, 2009). Bain and Cummings (2005) assert, national governments are increasingly concerned about their competitive share in the internationally mobile student market (p. 20). Two surveys conducted by the Pew Research Center (Taylor, Parker, Fry, Cohn, Wang, Velasco & Dockterman, 2011), one of college presidents and the other of members of the public, examined confidence in the U.S. American higher education system. Among the findings is a common sense of deteriorating confidence in the value and relevancy of higher education. In fact, half of the presidents surveyed indicated that they felt the United States was losing ground to other countries and would no longer be among the top leaders in ten years. While cuts in state subsidy and the economic downturn were cited as contributing factors, one point was made clear; the need for change (Fischer, 2011, May 15). Initiatives to better align the delivery of higher education to meet market demand are sweeping across the nation. It is likely that a hybrid model of higher education will become more common in future learning, where site-based and electronically delivered instruction and 5

6 support services will be offered together, whether from traditional institutions or new providers (Eaton, 2002, p. 4, as cited in Van Hook, 2011, p. 21). Most prevalent among non-traditional programs is the push toward online learning. According to Taylor, Parker, Lenhart and Patten (2011), college presidents predict substantial growth in online learning: 15% say most of their current undergraduate students have taken classes online, and 50% predict that 10 years from now most of their students will take online courses" (p. 7). NAFSA s International Student and Scholar Regulatory Practice Committee (ISS-RP) has identified a number of issues surrounding non-traditional programs (short-term, hybrid, lowresidency, distance/online, short-term ESL, professional training, etc.) and the ability to have non-immigrant participation in these programs. Most prevalent among non-traditional programs is the push toward online learning. For example, the Minnesota State Colleges and Universities Board of Trustees, which oversees 31 state colleges and universities, established a goal for 25 percent of all credits to be earned through online courses by Behind the initiative was Governor Tim Pawlenty, who observed, "we live in an ipod world but much of our education system is dominated by whiteboards and lecture halls" (Voss, 2008, November 08). Further south, Governor Rick Perry led the creation of Generation TX, a website designed to provide online resources for students to pursue higher education in Texas, a state with the third largest share of international students in the nation. Nationwide, 65% of higher education institutions include online learning as a key component of their long-term strategy, 31% of higher education students take at least one online course and an overwhelming majority of chief academic officers believe the level of student satisfaction with online courses is equivalent to face-to-face offerings. The ninth annual survey, a 6

7 collaborative effort between the Babson Survey Research Group and the College Board, reported that as of 2011 over 6.1 million students were taking at least one line course during the fall term of 2011, the number was 6.1 million in 2008 so the growth is significant. A 2010 article on the Chronicle of Higher Education reported that Ivy League universities which until recently were not pushing for online courses are changing their tone. According to the article leaders at the University of California want to be the ones with the initiative in spite of some opposition from a sector of their faculty. International students are a big part of the student population taking online courses but the current F-1 regulations limit the number of on line courses that they can take. If the future of U.S. higher education will involve taking a big percentage of courses online then the regulations must address how our international student can accomplish their educational goal without jeopardizing their status. The Task Force for Non-Traditional Programs was formed after a notice of its charge at the 2011 NAFSA annual conference in Vancouver BC, Canada. The task force members met over a conference call monthly beginning in early Fall 2011 in an effort to: 1) identify the issues that are arising with the increase of international programs that fall outside of the traditional degree-seeking norm, 2) formulate a questionnaire that colleagues could respond to in an attempt to identify variations of programs that are being offered, and their associated regulatory problems, 3) conduct a qualitative review of the responses to categorize the various kinds of programs and the immigration issues as a result, and 4) make recommendations on how the immigration challenges could be met with either existing visa categories or creations of new ones. 7

8 Charge of the Task Force: NAFSA s charge to this task force was to: A) identify and describe common non-traditional kinds of programs of instruction (or trends in programs of instruction) conducted by higher education institutions that were not envisioned in the current F and J regulations; B) identify and analyze how the current F and J regulations impede institutions ability to offer these programs to international students; C) identify current and potential impacts of these impediments for institutions, particularly with consideration for how the impediments affect U.S. institutions ability to remain competitive in the global marketplace ; D) identify and analyze issues pertaining to possible benefits of participation in nontraditional programs in B-1/B-2 status, providing comparisons as it pertains to administrating such programs in in F or J status for U.S. institutions, SEVP, DOS-EVP, and USDHS; E) recommend a course for liaison and advocacy with SEVP and other agencies. Data Collection The task force ultimately decided to survey educators in the United States to get a better sense of current issues and concerns. After reviewing the academic and professional literature and consulting experts in the field of international education, the team agreed upon the survey questions, which included three demographic questions and two questions focused on types of programs and associated immigration challenges. The web-based survey was sent out several times through NAFSA, AIEA, AAIEP, UCIEIP and various other listservs, as well as published in newsletters of post-secondary and higher education organizations dealing with international education exchange, intensive English, and related fields. It was also advertised at regional NAFSA conferences, regulatory update meetings, and other NAFSA venues. The online survey remained open from November 8

9 16, 2011 through February 26, The intent was to reach as many professionals as possible who had direct experience, successful or otherwise, in bringing in foreign nationals through nondegree programs. The survey received 361 responses of which nearly one-third indicated they had experienced immigration challenges. Open-ended questions were: 1) analyzed qualitatively three times using different criteria to insure accuracy in reporting results, 2) categorized according to immigration need, 3) discussed on a task force team level, 4) discussed in-depth in an open meeting at NAFSA s 2012 Annual Conference in Houston, Texas, and 5) articulated into recommendations for regulatory solutions. A copy of the survey is included in Appendix A. Results Approximately 35% of respondents indicated that they had some immigration issue related to non-traditional programs, and approximate 34% of respondents indicated they had considered offering programs that had not come to fruition because of regulatory limitations. Appendix B includes responses from the internet survey. The general consensus during the open meeting at the NAFSA 2012 Annual Conference was to address the regulatory issues in order to meet the rapidly changing needs of higher education. The types of challenges faced by campus administrators as a result of regulatory restrictions are presented in Figure One. 37.1% of respondents shared concerns over the appropriateness of the B-type tourist visa, 16.1% reported challenges associated with current regulations (i.e., F, J and M) and 12.1% cited visa delays and denials. Other issues accounted for less than 7% each. 9

10 Figure 1 Breakdown of Issues by Type Figure 2 displays the types of non-traditional programs affected by current restrictions. Half (50%) of all respondents cited short-term and summer programs, 22.4% mentioned noncredit and non-degree programs, and 13.3% shared concern over restrictions associated with distance learning. Other issues were cited by less than 11% of respondents. Figure 2 Program Types Affected 10

11 How current regulations limit the ability of institutions to offer nontraditional academic programs In many instances, designated school officials interpretations of regulations are very conservative. This is in part due to the ambiguity caused when emerging trends in higher education do not clearly fit existing policy. In some instances, designated school officials were successful in using the recertification process as an opportunity to explicitly include nontraditional programs on their institution s form I-17, but most felt that recertification was another area of ambiguity and did not wish to take additional risks. On many campuses, there is a shift toward low-residency models of program delivery. For instance, traditional courses may be required in the summer while only online courses are available in the fall and spring semesters. For these programs, international students are required to obtain a new visa each year in order to fulfill the summer residency requirements. This detracts from the attractiveness of such programs in the United States as it adds both cost and uncertainty given that the student needs to apply for so many visas. Similarly, there is substantial growth in short-term professional and intensive English programs. While current regulations allow international students to enroll in such programs so long as they constitute a full course of study, this does not always meet market demand. One respondent used the term educational tourism to describe these short-term programs that are so popular in other countries, but practically prohibited in the United States. Again, respondents felt the United States was at a disadvantage academically, economically and politically. Several respondents argued the regulations are driving the development of academic programs, which inhibits innovation. Others called for a follow up study to document how much money is lost to other countries during a time of economic recession. Finally, some respondents cited the inequity 11

12 between tourist and student visas. In their view, students incur greater financial costs and regulatory restrictions than tourists. Miscommunication regarding the administration of non-traditional programs There appears to be much confusion over international students participation in nontraditional programs. At the institutional level, respondents who serve as designated school officials expressed frustration in frequently having to be the bearer of bad news on their campuses. For instance, faculty and administrators often work carefully to design an innovative program, but when the designated school official is asked how to include international students, he or she is forced to state it is not possible given the limitations of current immigration regulations. During an open forum, one participant explained that campus administrators at his institutions were experiencing increasing pressure from the governor to create innovative academic programs designed to stimulate the state s economy, but he felt federal immigration regulations actually inhibited his ability to meet this charge. Other educators shared similar concerns. Beyond the institutional level, multiple respondents cited concern over receiving conflicting information from government agencies over how to allow international students to participate in non-traditional programs. In some instances, students were advised by Consular officials to obtain a tourist visa in order to participate in a part-time, summer program, only to be detained at the Port of Entry. How campus leaders are preparing At many institutions, international education administrators are proactively taking stock of current programs and initiatives offered at their institution while at the same time raising awareness among colleagues of restrictions associated with immigration regulations. For 12

13 example, several participants in the Open Meeting cited using the SEVP recertification process as an opportunity to meet with colleagues across campus to discuss issues related to nontraditional programs. In some instances, these meetings led to standing committees designed to specifically focus on ESL and Hybrid programs. However, Designated School Officials also reported frustration with feeling that although they proactively sought SEVP approval for newly developed programs, the delay in receiving a response inhibited academic programs directors ability to recruit internationally. Recommendations Four changes to DHS 1 regulations could substantially reduce the barriers higher education institutions face in offering nontraditional programs of study: 1. Allow Designated School Officials of colleges and universities to certify a full course of study for undergraduates F-1 students are required to pursue a full course of study leading to the attainment of a specific educational or professional objective (8 CFR 214.2(f)(6)(i)). There are a few very narrow exceptions, such as the possibility of a reduced course load for students with a documented illness or medical condition. The regulations provide several definitions of full course of study that apply to specific kinds of institutions and academic programs, including: Undergraduate study at a college or university must consist of at least twelve semester or quarter hours of instruction per academic term (8 CFR 214.2(f)(6)(i)(B)) 1 The need for DHS to issue F-3 regulations that facilitate study by commuter students is not addressed in this paper since another NAFSA task force is preparing a paper on the topic. It should be noted, though, that DHS has not yet issued regulations to implement the Border Commuter Student Act of [Pub.L (November 2, 2002) and the F-3 and M-3 categories. The Department of State promulgated such regulations in 2003 and, despite DHS assurances that it should not, began issuing visas. The lack of corresponding DHS regulations leads to many issues, problems, questions and concerns about the F-3 and M-3 classifications. 13

14 Study in an English as a Second Language program and certain training programs must consist of at least eighteen clock hours of attendance a week (8 CFR 214.2(f)(6)(i)(D)) The Designated School Official of a college or university certifies what constitutes a full course of study for graduate study (8 CFR 214.2(f)(6)(i)(A)) The Designated School Official of a conservatory or religious seminary certifies what constitutes a full course of study for both undergraduate and graduate study (8 CFR 214.2(f)(6)(i)(A)). No more than one class or three credits per term of online or distance education may be counted toward the full course of study requirement (8 CFR 214.2(f)(6)(i)(G)). The full course of study requirement severely limits the ability of F-1 students to participate in distance and online education. It usually prevents F-1 students from enrolling in low residency programs such as executive graduate degree programs and in hybrid programs that involve both classroom and online education components. It often prevents F-1 students from participating in short-term programs of various kinds, ranging from preparation or foundation programs to summer programs involving English language study and cultural activities or involving classroom study and an internship component. While the regulations allow the Designated School Official of a conservatory or religious seminary to certify (or determine) for the institution a full course of study for both undergraduate and graduate programs, Designated School Officials of colleges and universities are allowed only to certify a full course of study for graduate programs. The regulations prescribe full course of study for undergraduates at colleges and universities. This additional authority offered to Designated School Officials of conservatories and religious seminars seems to reflect the agency s understanding that these institutions offer programs that might be considered non-traditional. Since the very nature of higher education programs has changed so dramatically since the current regulations were written, and the current regulations so restrict colleges and universities in offering innovative programs and programs that are increasingly not considered nontraditional, the regulations should be revised to allow college and university Designated School Officials to certify the full course of study for both graduate and undergraduate students. The DHS Student and Exchange Visitor Program (SEVP) has stated that it may consider and approve on a case-by-case basis certain non-traditional programs like those described here. This is not, at least in the current environment, a workable solution. There are no established criteria for making such decisions. SEVP has been unable to process in a timely manner the many other kinds of adjudications that it now makes, and this has resulted in the accumulation of extensive backlogs and processing times of up to six months. It would not be reasonable to require an 14

15 institution to undergo a six month approval process before it can know that it may offer a program to international students, especially for special programs that may be offered once. 2. Revise the regulations pertaining to Visitors visa and collaborate with the Department of State to create a visa policy more facilitative of short-term educational activities Persons who need to travel to the U.S. for certain short-term education-related activities sometimes consider obtaining a Visitor visa to do so. The Department of State grants two kinds of Visitor visas, B-1 Visitor for Business and B-2 Visitor for Pleasure. The law defines a Visitor as an alien (other than one coming for the purpose of study...) having a residence in a foreign country which he has no intention of abandoning and who is visiting the United States temporarily for business or temporarily for pleasure (INA 101(a)((15)(B)). DHS regulations explicitly prohibit a Visitor from enrolling in a course of study (8 CFR 214.2(b)(7)). The regulations do not define course of study, but both legacy-ins and the Department of State have acknowledged that a short-term class, such as a single English language class, undertaken as an activity secondary to the Visitor s primary purpose in the U.S. may be acceptable (INS memo HQISD/ P, J. Williams (April 12, 2002) and 9 FAM N13.6). Some consulates issue Visitor visas to applicants who will participate in a shortterm summer English language program with a cultural component, particularly if the cultural component is more significant than the English language component, but other consulates do not. Even with the Visitor visa in hand, such a traveler may be turned away at the port of entry if the inspecting DHS official determines that she or he intends to enroll in a course of study. The statute provides examples of business activities such as conventions, conferences, and consultations that could be considered to include academic-related activities (INA 101(a)((15)(B)). Also, the Department of State s Foreign Affairs Manual provides that travelers intending to participate in scientific, educational, professional, or business conventions, conferences, or seminars or undertake independent research might be eligible for a B-1 Visitor for Business visa. Applicants are sometimes successful in obtaining a B-1 Visitor for Business visa in order to travel to the U.S. for a component of an educational program such as a meeting with an advisor or dissertation committee or even a brief on-campus component of an executive graduate degree program. Again, such a traveler may be turned away at the port of entry if the inspecting DHS official considers the intended activity part of a course of study. DHS should provide a regulatory definition of the term course of study, found at 8 CFR 214.2(b)(7), to facilitate a wide range of short-duration education-related activities that do not constitute a full degree or credential program. These would include short-duration vacation programs involving an English as a Second Language or other educational component, short visits related to a program of study in which the study component has already been completed (such as to meet with a dissertation committee or an advisor), and brief in-residence portions of 15

16 educational programs being pursued abroad or online and for which students cannot qualify for an F-1 visa. In discussions about either the difficulties of using the Visitor classification for education-related activities or the possibilities of expanding its use, some DHS officials have suggested that new legislation would be required and that the Department of State would be the agency involved in making changes. Pursuant to section 428 of the Homeland Security Act of 2002 and at least one Memorandum of Understanding, though, DHS plays a key role in establishing visa policy despite the fact that the Department of State manages the visa issuance process. DHS could work with Department of State to change visa policy so that the Visitor classification could be used for brief education-related activities. For example, a regulatory definition of course of study could be established that would not exclude short-term education-related activities. 3. Revise the regulations so that students are not penalized or placed in a precarious travel situation after program-related leaves of absence from the U.S. A DHS regulation provides that an F-1 student who has traveled abroad may be readmitted to the U.S. after a temporary absence of five months or less as a continuing student using the immigration documents previously issued, if unexpired (8 C.F.R (f)(4)). This regulation has been interpreted by SEVP to mean that after an absence of more than five months, a student may not be readmitted to the U.S. to resume status, but rather would have to enter as an initial student. An initial student is required to pay a new SEVIS (I-901) fee of $200 and obtain a new visa eligibility document from the school, and Department of State has indicated that a new visa is required even if the prior visa remains unexpired. The eligibility clock for certain benefits like practical training re-sets for students entering the U.S. after an absence of greater than five months, so such a student would be required to wait one academic year before becoming eligible for Curricular Practical Training (SEVP Travel FAQ, item 2.L.). This re-setting of the eligibility clock is a significant penalty for many students. As institutions in the U.S. establish overseas campuses and offer joint programs with institutions abroad, and as students find expanding opportunities to conduct field work and research abroad and participate in study abroad programs, more F-1 students face these significant burdens and uncertainties in returning to the U.S. to resume studies and then experience the eligibility clock penalty on return. SEVP has informally offered a narrow work-around in SEVIS for F-1 students who are conducting research in another country in furtherance of their educational program in the U.S. or are engaged in a study abroad program in another country. This has reduced the uncertainty and burdens that some, but not all students face, and it does not eliminate the eligibility clock penalty in many cases. 4. Revise the Curricular Practical Training regulations to facilitate experiential learning 16

17 After being enrolled on a full-time basis in a college, university, conservatory, or seminary for one academic year F-1 students may be eligible for Curricular Practical Training (CPT), through which they may obtain employment authorization from DHS to participate in certain kinds of experiential learning such as internships or cooperative education programs that are an integral part of an established curriculum (8 CFR 214.2(f)(10)). Graduate students enrolled in a program requiring participation in CPT are exempted from the one-year wait to become eligible. As institutions in the U.S. establish overseas campuses and offer joint programs with institutions abroad, an increasing number of undergraduate F-1 students arrive in the U.S. having completed a significant portion of their educational program but ineligible for CPT and unable to participate in required internships or benefit from the experiential learning that CPT may facilitate. The idea apparent in the regulations that a student must be present in the U.S. for an academic year to gain the academic background necessary for productive CPT is outdated and inaccurate. Therefore, the requirement that students complete one academic year of study before becoming eligible for CPT should be eliminated from the regulations The regulation should also be revised so that Designated School Officials need not parse the phrase integral part of an established curriculum before authorizing CPT, but can issue it for training related to the student s field of study. A better regulation would read An F-1 student may be authorized by the DSO to participate in curricular practical training that is related to the student s field of study. Furthermore, the word required should be removed from this phrase of the regulation: Curricular practical training is defined to be alternative work/study, internship, cooperative education, or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school. Students who have received one year or more of full time curricular practical training are ineligible for post-completion academic training (8 CFR 214.2(f)(10)). so that it clearly communicates that an internship or related training opportunity may be an elective and need not be required for completion of the program in order for the participating student to be authorized for CPT. Conclusion Campus leaders in the United States wish for their institutions to remain both relevant and competitive in the years ahead, but restrictions inhibiting international students participating in non-traditional programs places not only individual institutions, but the entire U.S. higher education system at a competitive disadvantage. The Task Force requests NAFSA s assistance in 17

18 advocating for a comprehensive review of current regulations restricting non-immigrant student participation in non-traditional academic programs. References Bain, O., & Cummings, W. (2005). Where have the international students gone? International Educator, Eaton, J.S. (2002). Maintaining the delicate balance: Distance learning, higher education accreditation, and the politics of self-regulation. American Council on Education: Washington, D.C. Fischer, K. (2011, May 15). Crisis of Confidence Threatens Colleges. Retrieved from Taylor, P., Parker, K., Fry, R., Cohn, D., Wang, W., Velasco, G. & Dockterman, D. (2011). Is college worth it?, Pew Social & Demographic Trends: Washington D.C. Retrieved from Taylor, P., Parker, K., Lenhart, A., Patten, E. (2011). The digital revolution and higher education; college presidents, public differ on value of online learning. Pew Social & Demographic Trends: Washington, D.C. Retrieved from U.S. Government Accountability Office. (2009). Approaches to attract and fund international students in the United States and abroad. (GAO ). Washington, D.C.: U.S. Government Printing Office. Van Hook, S. R. (2011). International learning institutions: organization, visions, and missions. Walden University: Minneapolis, MN. Voss, M. A. (2008, November 20). Governor Pawlenty and Minnesota State Colleges and Universities chair announce online learning initiative. Retrieved from 18

19 Appendix A: Survey Questionnaire 1. What is your institution type? a. English-language/private b. English language/university-operated c. Private/postsecondary d. Community college e. Technical school f. College or university g. Other. 2. Please indicate the programs your institution is authorized to administer (you may indicate more than one): a. M Students b. J Exchange Visitors c. F Students 3. What types of programs do you currently offer? (check all that apply): a. English language preparatory for university study b. Other English language c. Academic nondegree (e.g. full-time extension courses without English component) d. Academic nondegree in conjunction with English language e. Research preparation with strong classroom component f. Foundation preparation for university study g. MBA preparation h. Unpaid professional experience programs following English language program 19

20 i. Youth/travel camp programs, with or without English language component j. Summer vacation program, with or without English language program k. Professional development (e.g. leadership) nondegree, with or without English language component l. English language for professionals (e.g. doctors, lawyers, executives, business professionals) m. Other i. If you selected other, please specify: 4. Have you had immigration issues associated with any programs indicated above? a. Yes b. No i. If yes, please describe those issues. 5. Has your institution considered offering programs that have not come to fruition because of regulatory issues? a. Yes b. No i. If yes, please describe those issues. 6. Has your institution considered offering programs that have not come to fruition because of regulatory issues? 20

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