State Authorization of Higher Education Regulations: A sampling of adverse impacts for students and society

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1 State Authorization of Higher Education Regulations: A sampling of adverse impacts for students and society Decreased access to programs. o Norwich University: The regulations will have an adverse impact on student access to programs given the likelihood that some state regulations will create cost-effectiveness barriers for the university to teach students from specific states. It is likely the university will not be able to accept or continue students in educational programs if they reside in more restrictive states, effectively limiting access to programs that may be unique (e.g. military history and diplomacy) and not widely available. The problem extends beyond Norwich University in that similar programs from other universities will also become unavailable to students. Student choice will be restricted. o Regis University: Education options and opportunities for students will be more limited if institutions choose not to become authorized in every state. For health professionals, business professionals and education professionals, online programs can be better suited to busy lifestyles and if this option is curtailed or eliminated many working professionals will be pushed toward more traditional models that do not accommodate the adult professional student. As a result, some students will chose not to continue their education. Program specific accreditations have been an issue for some of our online students. For example Kentucky and Arkansas only recognize NCATE accreditation for teacher education programs and Regis is accredited by TEAC. In Kentucky step increases for master-level education students can be denied by the state review board if the awarding institution is not NCATE accredited. This variation from state to state is not a philosophical debate; this is a difference in practice that adversely affects student s livelihood. o Baker College Online: First, military students could experience a negative impact to the new regulation because of the frequent moves one makes during their career. This regulation adds another area in which the military students will need to be concerned during the application process and throughout their degree program. This is also true for any students that frequently travel or move often because of job requirements. There is also a potential negative impact for those currently enrolled at Baker Online if their state does not Baker Online to "operate" in their state. It could cause a major disruption to a student degree plan if students would be required to find another institution to complete their degree causing delays in graduation and financial penalties

2 if additional courses are required at the new institution. Students that face this situation may decide it is too difficult to finish their degree which in turn negatively impacts graduation and loan default rates. o Charter Oak State College: Charter Oak is a small state institution. State budgets are being cut back. If Charter Oak would have to pay to be licensed in all of the states, it could not afford to operate outside of Connecticut; therefore 40% of its students would have to find another nontraditional college to attend. o University of Wyoming: We offer a number of degree, certificate, and endorsement programs that are well-enrolled with Wyoming students, but we also have some portion (about 20%) of our distance students who are from outside the state of Wyoming. In fact, we have students in almost every state in the United States and have some from other countries as well. If we are not able to get states authorization for our distance programs, both out of state and Wyoming students can be negatively impacted because Sometimes we don t have enough in-state, Wyoming students to make a distance class(s) or program financially viable, so enrollments from out-of-state students increase the enrollments enough that are able to offer the classes. Please note that UW s distance programs, like most distance programs, are not supported in the same way as UW-Laramie main campus courses: 75% of the support for UW s distance programs comes from the tuition that students pay for the distance courses they take; only 25% comes from the state. Therefore, we can t offer many classes that lose money thus the need in some programs for out-of-state enrollments. IF we are unable to receive state authorization to offer these programs in other states because the process is too difficult or the cost too high, we may have to cease offering these courses outside the state of Wyoming; if we don t have the necessary enrollments in the courses or programs, we may have to cease offering them to in-state, Wyoming students as well. Thus, both in-state and out-of-state students may have reduced access to educational programs. UW has some unique programs offered at a distance, e.g., accelerated nursing degree program, land surveying certificate program, master s in speech-language pathology, and the certificate for teachers of American Indian children. These programs are not widely available from other institutions. Each of these programs provides students with both the knowledge and the certification to engage in occupations important for communities and the country as a whole. If UW is unable to offer these programs to out-of-state students, students access will be restricted to these important professional workforce learning opportunities. And, as noted above, if we have too few Wyoming students to make the courses financially viable, then we may not be able to offer them at all. Again, both in-state and out-of-state students will be negatively impacted. As well, communities will have fewer professionals in these professions. o Huntington Junior College: HJC is one of only sixty schools, across 28 states, in the nation to offer a Realtime Reporting program that is certified by the National Court Reporters Association. Students who cannot attend a campus based school must rely on one of the ten programs, such as Huntington s, certified by the National Court Reporting Program that can be completed entirely online. This program prepares students for careers as Court Reporters, Broadcast Captioners, and CART providers for individuals who are deaf or hard-of-hearing. If the State Approval Regulation of Distance Education is implemented, Huntington Junior College will have to look at each state s requirements to determine if the approval process is feasible. If not, the college will be forced to stop accepting students

3 from those states. One example of a state that would be cost prohibitive is Massachusetts. This state requires a $10,000 application fee and an additional $2,000 for each program you offer. Once approved there is a $4,000 annual fee. This cost does not include any fees associated with site visits. Massachusetts does not have a certified Realtime Reporting School in the state. If residents want to participate in this program, they must take classes online or relocate. Due to this regulation, their choices of educational opportunities will be reduced. Pass increased cost to students. o Norwich University: Costs of compliance in all 50 states will be substantial initially and in ongoing operations. Many states require various fees, bonds, physical offices/agents and other regulatory mechanisms regardless of online delivery systems, and renewal cycles vary but will require constant attention to maintaining currency. Direct costs and additional staff resources will necessarily be reflected in tuition and fees and contribute to the student financial burden. o Regis University: It is reasonable to think that the cost of state certifications will be passed along to students and further exacerbate the rapidly increasing costs of tuition. o North Dakota University System Online: performed a financial analysis of how much it would cost for one institution in North Dakota. The institution serves 615 students in 48 other states. The institution needs to apply in 21 states and to register in four more. The rough estimate for the total cost in fees for this one institution to apply or register for approval in those 25 states is $159,800. This analysis focuses solely on fees and does not include the staff time necessary to research the regulations, complete the applications, and manage the process. o Minnesota State College and Universities: performed a similar analysis to North Dakota s for the 32 colleges and universities of the Minnesota State College and Universities of what the first year would cost if all the system s colleges and universities sought approval in the other 49 states. Based upon preliminary estimates of the states where approval or registration would be required, it is estimated the total cost in fees would be $5.5 million. o Bismarck State College: During any given semester we deliver courses to all fifty states. While the majority of our students are North Dakota residents, roughly 83%, the tuition and fees we collect from out-of-state students through our online programs provides us funding to develop better online instruction or to enhance directly our on-campus programming. A sampling of state approval costs estimated and the number of students served by BSC in those states: Minnesota o 59 Online Students, 3 Military Students, 44 Energy Students o Application Fees: $2,000 per Associate s Degree, $2,500 per Bachelor s Degree. o 13 AA/AAS degrees = $26,000 o 1 BAS degree = $2,500 o Total = $28,500 Wisconsin o 22 Online Students, 1 Military Student, 21 Energy Students o Application Fees: $2,500 per Associate s Degree, $3,300 per Bachelor s Degree. o 13 AA/AAS degrees = $32,500 o 1 BAS degree = $3,300 o Initial Total = $35,800

4 o Annual renewal fee - $500 Annual Renewal of School and Program Approval Florida o 37 Online Students, 7 Military Students, 36 Energy Students o Application Fee: $500 plus $3,000 Workload Fee plus $200 per program ($2,800) o Total = $6,300 Alabama o 3 Online Students, 1 Military Student, 3 Energy Students o Application Fee: ½ of 1% of annual gross income from AL students, not less than $2500. o Total: $2,500 Alaska o 4 Online Students, 2 Military Students, 4 Energy Students o Application Fee: $2,500 plus renewal fee of 3% of average tuition receipts during most recent authorization period (not less than $500). o Total: $3,000+ A base total of only these 5 states is $76,100+ in cost for 257 students (Approx. $296/per student) Decreased access to faculty. o Norwich University: A significant part of the educational process at Norwich University is mentoring and relationship building that occurs between students and faculty, many of whom are experts and well known in their field. Online programs allow the recruitment of the best faculty available regardless of physical location; to restrict access to programs restricts access to faculty. For example, our military history program enjoys participation by the top military historians in the U.S.; student access to this faculty would be curtailed or seriously limited under the new requirements. Decreased earning potential for students. o Charter Oak State College: We don t have the evidence of income gain our out-of-state students make, but we know that once a CT student graduates, their income, according to the Department of Labor, increases by 46-51%. Therefore, the implementation of this federal requirement will have an impact on the economy as a whole and on the earnings of individuals. o Huntington Junior College: Huntington Junior College is one of ten programs in Realtime Reporting that can be completed online. This program prepares students for careers as Court Reporters, Broadcast Captioners, and CART providers for individuals who are deaf or hard-ofhearing. The US Department of Labor reports that career opportunities in captioning and realtime reporting are expected to grow by 9% to 25% by According to the National Court Reporter s Association, the average salary range for broadcast captioners is $45,000 - $75,000. Decrease in diversified student experience. o Norwich University: A significant benefit of online education is the ability to be exposed to people and ideas from around the country and world. Our experience has been that this is a powerful educational element that has benefited many of our online students both directly

5 through new contacts and indirectly through general exposure to different perspectives. Opportunities to experience a greater diversity of ideas will be diminished under the new regulations as students from whole states or areas of the county may be excluded from programs and educational opportunities. Decreased availability of experiential learning opportunities. o Norwich University: Distance education has become an important approach to facilitate experiential learning experiences beyond the borders of Vermont. Undergraduate students matriculated in degree programs that have internship and field experiences will be adversely affected should regulations in a significant number of states preclude the ability to be placed there. Adverse rural impact. o Norwich University: Finally, rural areas will be disproportionately and adversely affected by the new regulations to the extent that programs not offered in a more rural state or region may be off limits to students. This hurts the individual student and economic development potential for a state or region. The restrictions some states may impose through regulations will also have the effect of being trade barriers. o Regis University: Rural students will be additionally disadvantaged if institutions chose to not become approved in every state Adverse Societal Impact: o Huntington Junior College: In addition to limiting access to educational opportunities, this regulation is going to have an unintended negative impact on the nearly 37 million adults who have hearing impairments in the United States (Center for Diseases Control & Prevention). As captioners provide realtime translations of the spoken word for these individuals, their services are vital to ensure Americans who are deaf or hard-of-hearing have equal access to information. Unfortunately, with fewer educational opportunities available, fewer students will be graduating realtime reporting programs. This lack of graduates will greatly impact the ability to provide Captioning services to Americans who are deaf or hard-of-hearing. o Regis University: For Health professionals: Research shows that better educated nurses lead to better outcomes for patients; states may inadvertently be hurting their populace. The Institute of Medicine s Report (October 2010) on the Future of Nursing addresses the need to raise the education level of the nursing workforce and to enhance nursing s leadership role in healthcare reform. The report charges nursing schools to increase the number of nurses with baccalaureate degrees from 50% to 80% by 2020; to have at least 10% of baccalaureate program graduates enter master s or doctoral degree programs within five years of graduation; and to double the number of nurses with a doctorate by State approval regulations will adversely affect achievement of these goals