We are encouraged that the Department's proposal would generally require all providers of distance education to obtain state authorization in each state where they intend to enroll students. However, we have concerns that distance education students could still be subject to weaker protections under the proposed rule, for the following reasons:

  • The proposal would permit state authorization through the use of interstate reciprocity agreements that could restrict a state's authority to protect its own students and students' ability to protect themselves
  • The proposal would permit providers to enroll students in professional certificate or licensing programs that lack the required accreditation for students to practice the profession in the students’ home state.

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