From the full comment letter:

As more borrowers than ever migrate to online platforms, the Department’s role in ensuring program integrity is even more vital. The consensus language in the NPRM represents the best compromise between industry, innovators, and borrowers. If it is changed at all, it should be strengthened, not weakened. The final rule should include the consensus definitions regarding regular and substantive interactions, retain the consensus agreement to limit the portion of a program that may be outsourced to 50% (with accreditor approval required above 25%), and prohibit institutions from artificially inflating program time in order to charge more in federally subsidized tuition.

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