2. Dr. Pamela K Shay, DBA
 Vice President for Accreditation & Institutional
Effectiveness
 Franklin University - non-profit, private institution
 Online & onsite academic offerings
 Students in 48-50 states at any point in time
Sharyl Thompson, MS
 External Regulatory Affairs Manager
 Capella University – for-profit, online institution
 Students in all 50 states

3.  Share our combined years of experience in
managing state authorizations for two
different types of institutions
 Share best practices of the management of
state authorization processes
 Provide insights and experience on
approaches to successfully navigate the state
authorization environment

4. Federal government published new regulations
Exposed existing requirements for state authorization
Institutions
Many unaware they are regulated
States
Unaware of institutions operating in their jurisdiction
Result
Confusion and degree of panic for institutions
Recent Activity
District court “vacating” portion of regs; DOE appeal

6.  Misconception that authorization is required
only for distance education
 There are a number of triggers, including but
not limited to:
o Students residing in a state
o Faculty residing in a state
o Recruiting and advertising
o Testing sites
o Internships, practica, or clinicals
o Branch campus located in a state

8.  Start with official regulations
◦ Multiple resources are now available, but the
foundation is what the regulations say
◦ Regulations are not always clear and are subject to
interpretation
 If, where, and how to seek authorization
depends on several factors including:
◦ Type of institution
◦ Delivery formats
◦ Types of activities conducted within states’ borders
 Create your own table

9.  Understand the states’ terminology
 Adjust your terminology to match the states’
Higher
education
To Educational institution
Physical services
operate Agent
presence
 Exemption provisions

10.  Have multiple people providing information
 Need one overall “manager”
Manager
A B C
• Detail oriented • Strong understanding • Strategic perspective
• Multi-tasker of entire institution • Facilitates decision
• Strong project • Connected with making regarding
management skills people across gray areas
• Typing and formatting institution • Participates in risk
skills • Condenses large analysis
volume of info into
useable documents/
sections

11.  Need info from all areas of the institution,
including (not exhaustive list):
Enrollment &
Marketing Recruiting
Admissions
Institutional
Finance Catalog
Reporting
Library & Faculty Curriculum
Student • Credentials
• Development
• Hiring
Services • Assessment
• Development

12.  Develop relationship with state regulators
 First review regs and requirements, then
approach with specific questions
 Understand regulators’ work load and
perspective (consumer protection and
enforcement of regulations)

13.  Attend regulatory meetings and conferences
(federal, state, agency)
 Serve on state/national task forces
 Represent your institution at meetings and
conferences (WCET, CHEA, AIUCO, NASASPS)
 Network across agencies and institutions

14.  Number of students in a state
 Activities institution wants/needs to conduct
(internships, recruiting, advertising)
 Fees for initial approvals, renewals, bonds, etc.
 Cost of not serving existing students
 Cost of monitoring and maintaining
authorizations
 These are strategic decisions and involve risk
assessment

15.  Ongoing authorization work
◦ Reauthorizations
◦ New program approvals
◦ Enrollment/revenue reporting
◦ Surety bond updates
◦ Agent licenses and renewals
 Ongoing work for exemptions
◦ Fees, enrollment reporting, reapplication
 Develop a system of regular review

16. Contact Information
Pamela K. Shay Sharyl Thompson
Vice President for Accreditation & External Regulatory Affairs Manager
Institutional Effectiveness Capella University
Franklin University Capella Tower
201 S Grant Ave 225 South Sixth Street, Floor 9
Columbus OH 43215 Minneapolis, MN 55402
shayp@franklin.edu sharyl.thompson@capella.edu
614.947.6135 612.977.5449