Lest I Understate The Issue

9 replies
  1. Glen McGhee, FHEAP
    Glen McGhee, FHEAP says:

    Yes, Phil runs the risk of understating the challenges OPMs face if the exemption goes away.

    Especially in this regard:
    Third-Party Servicer – Providing any percentage of a Title IV-eligible program at an institution, including:
    — Establishing requirements for the completion of a course and/or evaluating whether a student has met those requirements;
    — Delivering instruction or mandatory tutoring;
    — Assessing student learning, including through electronic means; or
    — Developing curricula or course materials, unless the institution maintains full control of the curriculum/materials and delivers the instruction itself.

    Most of these activities are subject to accreditation standards and accreditation review during reaffirmation.
    The problem is, Third-Party Servicers doing any or all of these activities are NOT accredited — only the partnering institution is accredited for Title IV purposes.
    I have always viewed third-party involvement as an attempt to **evade** accreditation review, since these activities fall under the radar when it comes to accreditation standards and accreditation review.
    Third-parties will cross the line into non-compliance with Sec. 602.16 when this does *not* happen: “unless the institution maintains full control of the curriculum/materials and delivers the instruction itself.”
    When will the ED results be tabulated and made part of the public record? I can’t wait!

  2. Patrick Perry
    Patrick Perry says:

    Phil do you seeing this as also extending to the ERP/SIS purveyors: Ellucian, Peoplesoft, Workday, whose integrated software systems that manage a lot of student interactions (many that have student retention modules in them)? These systems usually act as the core admin integration for most campus IT environments.

    • Phil Hill
      Phil Hill says:

      Patrick, (I’m not a lawyer, yada, yada)

      In a word, yes. That same table that I called out regarding LMS seems to apply to ERP/SIS.

      “Providing computer services or software in which the provider has access to, or maintains control over, the systems needed to administer any aspect of the Title IV programs, whether through manual or automated processing, including, but not limited to, systems related to financial aid management, recruitment and enrollment, admissions, registration, billing, and learning management.”

    • Phil Hill
      Phil Hill says:

      Great point – I’m not sure on this one, as it is not clear where the line is drawn between the core application and educational usage design. But of course, that’s part of the problem with this Dear Colleague Letter. LMS, ERP/SIS, tutoring, advising – systems designed for educational usage at HE institutions – seem much more clear.

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