A long over due and critical need for institutions serving students that have moved from our state or students that find us from other states. I wonder if the compacts should be more closely aligned with the accrediting agencies. They have mechanisms that could be used to verify quality and communicate findings to the home state without much additional work on their part.

This is an important step to simplify licensing for online institutions as well as to ensure quality across state lines. Forcing institutions to acquire licensing in multiple states is not only unwieldy and costly not to mention not being in the best interest of providing access to educational opportunities. Does this agreement cover both degree granting institutions as well as vocational institutions or non-credit baring institutions?

I too wonder if the compacts should be more closely aligned with the accrediting agencies. However, it is my understanding that accrediting agencies provide academic quality assurance, they don't necessarily monitor consumer protection as closely as states do.

This is tremendously important work and a change in policy cannot come too soon. There are many geographic areas that are underserved in terms of physical access to advanced or specialized health education programs. Restricting access to legitimate distance programs does, indeed, affect the health of the people who live in those communities. What is the proposed timeline for moving this initiative forward? Again, thank you for your excellent work thus far.

Definitely a step toward "sanity" in this discussion. I particularly appreciate the clear definitions of activities that should not trigger "physical presence" within a state.

One question remains for me, though: what is the motivation of any individual state to submit itself to the reciprocity agreement? After all, many of the state authorization regulations seem to be written with a "wow--we can charge a LOT of money for this distance ed thing, and it's like free money" mentality. What's to convince a state like Wisconsin that foregoing the revenue from its "your fees will be a combination of tuition you charge in our states + fees per program you offer + fees based on enrollment" structure is a good thing? Imagine the legislator who sponsored the bill that adopted or supported the reciprocity agreement, even though it basically said "I know we're going to lose a lot of revenue, but that's okay, because all the other states are losing revenue too, so it will work out in the end." Call me cynical, but I guess I just don't see it happening.

Well, it is and it isn't good news. Just because many powerful people in higher education, and those inside the Sloan Consortium, want to make changes, my prediction is there will never be a nationwide agreement. From my experience, too many states are too engrained in their state laws, express the belief that only their states will control their higher education (much as a result of the feelings instigated with NCLB), and simply the steadfastness to protect their valuable market of higher education is very great. I am taking an unenthusiastic stand on this initiative.

Currently, there are roughly 16-18 states where state authorization (SA) is fairly easy and inexpensive, another 10-15 that are easy but fairly expensive, and a good 15 that are 'ridiculously' expensive and time-consuming (and others that just don't answer phone or email correspondence). Moving that high-end of trouble into an agreement for ease will be challenging, to say the least.

It is that physical presence factor, or as I have seen it referred to, "stepping into our state," that causes so many legal issues. For instance, if this initiative were to pass, would that make it easier for any university to simply build another college in Oregon, Alabama, or Texas? At what degree of physical presence intrusiveness legally separates F2F teaching, offices, recruitment, buildings, campuses, or full colleges and universities? And not only must we ask how are they going to determine this, but we must also ask what will be the point of demarcation?

My prediction is that many states will join and make an agreement, others will not. State authorization for distance education, in my opinion, will never go away.

Where we can upload the document with comments annotated so the comments are in context.

You can join the discussion in the Sloan-C commons (see the links to the left) and add a document to the group - I think I've already added yours here : http://commons.sloanconsortium.org/node/70396/content/documents - don't forget to join the group!