Part 3: Consumer Protection

Recommendations:

3.1 Reporting Requirements

A. A state serving as an institution's home state for purposes of the interstate reciprocity agreement should confirm that the institution is in fact providing to current and prospective students (and, where applicable, to IPEDS) the information that is required for Title IV disclosures and reporting. This encompasses current required disclosures and reporting requirements as well as any future requirements that the Department may adopt.

B. If an institution does not participate in Title IV, its authorizing state should require the institution to post the same information required for Title IV participation on the institution's website as a condition for participating in the interstate reciprocity agreement.

3.2 Complaint Mechanisms

A. A state should agree to receive and resolve consumer protection complaints filed against institutions that the state authorized for purposes of interstate reciprocity. In so doing, the state may not limit the jurisdiction of other involved states (e.g., the student's home state), but agree to serve as the default forum for student complaints. States that are designated as the home state of an institution for purposes of interstate reciprocity should serve as this default forum for that institution. Other involved states and accrediting agencies should remain free to receive and resolve consumer complaints as well.

B. A state should confirm that the institutions that it authorized for purposes of the reciprocity agreement are in fact providing enrolled students with clear information about how to file a complaint and with what entities complaints may be filed. At a minimum, this information should be provided on the institution's website and through direct communication when the student enrolls in a distance education program authorized as part of the reciprocity agreement.

C. To respond effectively to complaints and ensure transparency, states should communicate and share complaint histories with other states and accrediting agencies involved in the reciprocity agreement. 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 of adverse actions regarding distance education or the accreditation status of a program available through distance education or of the institution as a whole to relevant home-state agencies and the general public on a timely basis.

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