"Regarding State Authorization of Distance Education providers enrolling students across multiple states, we voice here our support for those provisions of the NPRM that preserve the State Authorization rules finalized in 2016 and currently in effect. The 2016 rules provide core protections to consumers and protect states’ rights to enforce their own laws in two key areas. First, the rules set requirements for reciprocity agreements that would require compacts like NC-SARA to raise their minimum uniform standards and clarify that states must retain their rights to enforce postsecondary-specific laws with respect to out-of-state online programs and schools. Second, the rules establish specific consumer disclosure requirements around state authorization, how a student can make a complaint against a school, and whether the online program meets certification/licensure requirements where the student resides. These disclosures help students avoid investing time and money, including that of taxpayers through federal financial student aid, completing an online program from a school that is based in one state, when that program fails to meet licensure/certification requirements, for nursing, for example, in the state where the student resides and wishes to work."

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