Part 2. Roles of Participating Entities

Recommendations:

2.1 Role of the Regional Compacts

A. As a preliminary step, all four regional compacts should agree to adhere to the standards and responsibilities involved in the interstate reciprocity agreement. These standards and responsibilities should include a process for admitting states to the interstate reciprocity agreement and determining whether any additional fees are necessary for current compact member states and/or non-member states seeking to join a compact for the limited purpose of participation in the interstate reciprocity agreement. The reviewing regional compact should ensure that states have both the authority and capacity to adhere to the requirements of the interstate reciprocity agreement.

B. To implement the interstate reciprocity agreement, regional compacts should accept state requests to join the agreement and admit states that have adopted the appropriate legislation and/or regulations to facilitate compliance with the requirements of the reciprocity agreement.
C. After the agreement has been implemented, regional compacts should perform the following functions: (1) maintain a public list – easily accessible to students – of states and institutions that are part of the agreement (this list should be comprehensive and available on each regional compact's website); (2) facilitate the agreement's continued growth and expansion to more participating states; and (3) monitor states’ compliance with the reciprocity agreement, including admitting, performing a biennial review of, and expelling states from the agreement. The heads of the four regional compacts should use the meetings of the national coordinating board to facilitate a regular exchange of information regarding state compliance with the interstate reciprocity agreement as well as the standards and responsibilities of the regional compacts themselves.

2.2 Role of Participating States

A. As a preliminary step, states that wish to join the interstate reciprocity agreement should take necessary action to comply with the requirements and standards of the interstate reciprocity agreement. Once admitted to the interstate reciprocity agreement, states should notify institutions that are likely to designate them as their home state about the interstate reciprocity agreement, its terms, and potential benefits to institutions. (Additional guidance about these steps is presented in Section III.)

B. To implement the interstate reciprocity agreement, states should authorize for participation in the agreement institutions that wish to participate in the agreement and meet the standards and requirements of the agreement. (States are encouraged to use existing structures and agencies for this process.)

C. After the state has authorized an institution for participation in the interstate reciprocity agreement, it should (1) notify the regional compacts of the institutions that it has admitted to the agreement in a timely manner; (2) reauthorize participating institutions on an annual basis; (3) monitor the compliance of the institutions it authorized for participation in the agreement with requirements regarding institutional quality, consumer protection, and fiscal viability (as described in the recommendations below); (4) take appropriate action against an institution it authorized if that institution fails to comply with those standards and requirements, which may include an investigation, citation, suspension, or expulsion from the interstate reciprocity agreement; and (5) notify the relevant regional compact of any adverse action taken against an institution related to the interstate reciprocity agreement in a timely manner.

2.3 Role of Participating Institutions

A. As a preliminary step, institutions that wish to participate in the agreement should apply to their home state for admission into the agreement.

B. The interstate reciprocity agreement should be triggered for participating institutions when out-of-state students enroll in the institution's distance education courses. Students should be made that the institution is authorized to offer those courses through the interstate reciprocity agreement, possibly by a symbol on the institution's website and/or a standard statement used by all participating institutions.

C. To maintain the agreement, institutions should comply with the standards and requirements of the agreement.

2.4 Role of Accrediting Agencies

A. As a preliminary step, federally recognized accrediting agencies for distance education purposes should monitor whether institutions they accredit are domiciled in a state that plans to join or has joined the agreement.

B. To implement the interstate reciprocity agreement, accrediting agencies that are federally recognized to accredit distance education programs should provide confirmation, when requested by the state, about the accreditation status of institutions seeking to participate in the agreement.

C. To maintain the agreement, accrediting agencies should continue to revisit and revise their standards for higher education to take into account the changing landscape of distance education. Additionally, in light of the reliance of states and institutions on accreditation as the primary means of quality assurance and in order to increase awareness of accreditation processes and decisions, all regional, national, and programmatic accreditors should be urged to provide a summary to relevant states of adverse actions with regard to distance education taken relative to institutions or programs to relevant home-state agencies on a timely basis. (See also Recommendations 3A, 3B, 3C, and 4.2C, below.)

2.5 Role of the National Coordinating Board

A. As a preliminary step, a national coordinating board, comprised of an odd number of members representing the full spectrum of the higher education community, should be established. The following principles should guide the establishment of the board:

• Members should come from the range of impacted groups to assure a wide range of support as the interstate reciprocity agreement is promoted and implemented, while also taking into consideration the need for those groups to have a permanent voice. Members should be drawn from all institutional sectors (including large- and small-scale distance education providers), regional and national accreditation agencies, and state officials including state regulators, state attorneys general, and state higher education executive officers.
• Though the board should represent a diverse set of perspectives and interests, roughly mirroring the composition of membership of the Commission on the Regulation of Postsecondary Distance Education, membership should not be driven by numerical representation or delegated interests. Instead, members should be selected based on their knowledge of the field, ability to work across multiple perspectives, and commitment to the collaborative work and success of the national coordinating board, consistent with the principles set forth herein.
• The presidents of regional compacts (or their designees) should be voting members with an important but not controlling role, e.g., the representative of a regional compact could be the vice chair of the board but not the chair.
• Members should have staggered terms.
• Members should have term limits.

B. To implement the agreement, the national board should advocate for the expansion of the agreement and adhere to three core principles of operation: maintenance of a limited role within the overall governance of the agreement, responsibility for communicating information to the field, and representativeness of all stakeholders.

C. To maintain the agreement, the national coordinating board should (1) focus on ensuring inter-regional alignment with the reciprocity agreement; (2) hold meetings at least twice per year; (3) produce an annual report on the state of the interstate reciprocity agreement; (4) establish a mechanism to resolve disputes between regional compacts about interpretation and enforcement of the agreement when they arise; and (5) be accessible to the higher education community at large to address concerns and questions as they arise (including appeals from states that are expelled from the agreement by their regional compact).

2.6 Accreditation and Institutional Quality

A. Based on accreditors' compliance with federal regulations and specific review of distance education programs in light of recognized quality standards, states should view institutional accreditation (including accreditation for offering distance education programs) by a federally-recognized accreditor as a sufficient guarantee of academic quality in distance education programs offered in the state under the interstate reciprocity agreement.

B. To participate in the reciprocity agreement, states should require that institutions seeking authorization to participate in the interstate reciprocity agreement demonstrate institutional quality by attaining accreditation by an accreditation agency that is federally-recognized to accredit distance education programs. States should confirm an institution's accreditation status with the institution's accrediting agency.

C. Federally-recognized accreditors that accredit institutions participating in the reciprocity agreement should consider the unique facets of distance education as part of a comprehensive review of institutional quality and revisit and revise their standards as needed to reflect changes and innovations in distance education.

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