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this conference will now be recorded hi everybody welcome to the August sand coordinator call pleased that you all could be with us today we have a very jam-packed agenda for today I'm very excited about it I have to tell you upfront though the order that you receive the agenda that is not the order that we're going to be doing today we have some special guests who are joining us and we're going to work that through to help to accommodate them probably the most important thing that I need to tell you before we get started is that I would really appreciate everyone who is not speaking to have their have their computers or their phones on mute because sometimes that really sets up for some background noise and also please make sure that if you leave your phone that you don't put us on hold because sometimes that puts forward some music that your institution may be using in the event of a hold so without further ado we're gonna get started so welcome again to the August call and our first very special guest today is Van Davis and I'm very pleased many of you know van he has been he has spoken with us before and today he is willing to come talk to us a little bit about the most recent Department announcement about borrowers defense to repayment and the proposed regulations so I think that he is a perfect candidate to help us untangle what was in that announcement so I'm gonna turn this over to van and he's given me some slides to be able to share along with that van do we have you with us you do can you hear me Cheryl yes I can you sound great thank you so much for being on here before I let him talk though I had to brag about him a little bit so van is the principal of I'm going to pronounce this wrong fog LOM Consulting LLC where he navigates colleges universities nonprofits and policy makers to understand where higher education is heading and how to navigate that future as you all may know he has spent over 20 years and hired educationist faculty member academic administrator policymaker in consultant after spending a decade as a history provides professor mo please make sure you're on mute okay folks as a history professor at both public and private colleges he joined the Texas Higher Education Board where he was responsible for distance education policy the state's multi-million dollar course redesign and faculty development programs and organized the state's annual reinventing struction and learning conference sorry I got lost for a second additionally van worked with open education resources and oversaw the development of the state digital learning objects repository I'm sorry we're getting a little feedback from some folks who do not have themselves on mute so I really would appreciate if you had put yourself on mute because it's a little distracting okay so as I was saying and I apologize for the disruption here much advance time the Coordinating Board focused on expanding higher education access especially for returning adult students he created grad Tech's TX Texas the state's audit degree completion project as well as the Texas affordable baccalaureate project which resulted in the development of the state's first public competency-based education bachelor's degree and the first multi institutional common sea based program in the nation most recently vans served as the associate vice president of higher education policy and research at blackboard where he focused on federal education policy and helped a variety of internal and external stakeholders respond to challenging challenges our work on student access and success affordability compass the education learning technology workforce development and change management he currently serves on the board of peloton you a 501 C 3 that provides academic and social support services for post traditional students enrolled in online common sea based education degree programs and so van is a trained facilitator sought-after speaker as we know have the over the last several years he spoken EDUCAUSE OLC accelerate up CEA's summit for online leadership WCE T's Leadership Summit and annual meetings Texas distance learning Association u.s. distance learning Association CB exchange international freedom from women and e-learning innovations in online learning as well as speaking in numerous faculty development workshops man is often asked to speak about the future of higher ed competency-based education college access affordability pedagogical practices for online learning and the impact of federal and state policy on higher education additionally man is authored a number of white papers and reports has served as a contributing editor for The Journal of competency-based education estefy before several legislative committees man holds a PhD in MA in twentieth-century US history with an emphasis on civil rights history from Vanderbilt University as well as a BA in history from Southwestern University he has been a professor at Truman State University Southwestern University and huston-tillotson University where he taught a wide range of lower and upper division courses as well as serving as outside member of an IDI doctoral committees man currently lives in Austin with his beloved wife the lowrider lease Estes and their three cats where he spends his free time cooking reading in his hammock camping building Lego models and dreaming about returning to Burning Man which he attended this time last year so with now we will it man take it from here and share with us what he will about borrowers defense to repayment thanks a lot Cheryl and yeah I was thinking today this time last year I was somewhere between Las Vegas and the Black Rock Desert and it was much much hotter than it is where I'm sitting in my air-conditioned office in Austin so glad I could talk to you guys for a few minutes this morning or afternoon depending upon where you are and thanks for the flexibility and letting me go first I actually have a board meeting for peloton you that I need to be at in a couple of hours this afternoon Cheryl asked if I would just talk really briefly about what's been going on with the borrower defense to repayment regulations since there's been quite a bit that is shifting as we speak and especially since there's still two days left for the public comment period if you are so inclined to do so and have not done so yet sure I'll just logistically really fast are you him are you in control of the slides or am i I'm in control and I'm happy to move it along as you like okay thank you if you could go to the the next slide then please so real quick recap on what borrow defense to repayment was at least at one time it was created in 1995 and it was relatively unused until 2015 and the collapse of Corinthian Colleges and to give you an idea of how relatively unused it was between 95 and 2015 there were probably a less than 10 claims per year since 2015 the Department of Education has indicated that there have been over a hundred thousand claims so something that was originally developed actually as a stopgap measure for the field the federal employment federal family education loan FF L programs it was never supposed to be a long term solution I was supposed to be sort of a one-year stopgap and then a negotiated rulemaking process would take place after that to put in permanent regulations that actually didn't happen and so it wasn't until 2015 after Corinthian Colleges collapsed and we started seeing a lot of students taking advantage of the program that we saw the Obama Department of Education engage in negotiated rulemaking and then proposed regulations released in 2016 those proposed regulations never went into effect had they gone into effect this is basically what they would do they would have allowed for loan forgiveness in Moss which is what has been happening actually since 2015 where there groups of students that are having loans forgiven and they're not necessarily required to initiate the process individually it would have forbade institutions from barring students from pursuing class-action lawsuits this is fairly important because this is something that was specifically targeted in the revised regulations that the department is asking for public comments on right now those 2016 regulations would have eliminated a statue and limitations on relief would have established several triggers for requiring institutions to provide the department with letters of credit it would have restored Pell eligibility to students at close colleges and this is also something that's that's pretty significant given the the current proposed regulations the 2016 rates would have allowed students an automatic discharge of their loans due to an institution's closure if the students did not reenroll in a program after three years they would have seen loans discharged and would not have had to have done anything at all as I said the proposed rules which should have gone into effect last year did not go into effect in Davis's Department of Education and they were delayed and instead a negotiated rulemaking process was engaged in between late 2017 and early 2018 and we saw at the end of last month that the Department of Education then released the new proposed regulations that are out for public comment right now sure it would you move to the next slide so one of the things that is very telling about this this the the context for what we're seeing happening with our defense to repayment is also the larger context is the deregulation that we're seeing happening at the department in general whether that be the borough defense to repayment whether it be what I'm sure Russ is going to be talking about in terms of taking a look again at semester credit our regulations whether it be income this is all part of a philosophical push from the Department of Education around deregulation about this time last year Betsy DeVos spoke at the mechanic Island Michigan Republican Conference and you may remember that some of the things that she said got quite a bit of play at the time especially in inside higher ed and chronicle of higher ed and again I think it's important to sort of understand that this is the larger context for what's pushing the current discussions she said the time of Washington knows best is over this approach didn't work it has not worked and it will never work president Trump and I know our jobs it's to get out of the way and then this is the sort of really infamous statement that she made specifically about the barware defense to repayment rigs while students should have protections from predatory practices schools and taxpayers should also be treated fairly as well under the previous rules all one had to do was raise his or her hands to be entitled to so-called free money and so this really I think caps eliza's the philosophical intent of the current proposed regulations it is an attempt to deregulate the industry it is clearly an attempt to focus on school and taxpayer fairness and the whole week we hear that tax payer fairness come up a lot with this idea that taxpayers shouldn't be on the hook for loans that have been defaulted on by students that shouldn't be on the hook for the money that students were given as loans if a student if an institution then closed or defrauded that in that individual but it's also I think indicative and it's something we see in the proposed rules it's also indicative of this philosophical belief that my education is really probably a private good and not a public good the public has talked about in terms of taxpayers and stewardship of funds it's not the higher education is not being talked about for the most part in terms of providing a general public good and I think that's important to say upfront because it is definitely one of the things that is shaping the proposed regulations Cheryl would you go to the the next slide please so what are the proposed regulations the regulatory purpose as the department defines it I think is really interesting they want to create clear consistent and transparent process for borrowers who have been harmed by their schools misconduct to seek to seek debt relief they believe the department has been very clear that they believe that the current regulations are not clear and that they are not very concise and they're difficult to move through and not efficient they want to we see this language again here better protect the interests of taxpayers and then this is something that I think is is important for us the proposed regulations include measures that support prospective and enrolled students in their obligation to be informed consumers and responsible borrowers and they elaborate on that by saying that the department's goal is to enable students to make informed decisions prior to college enrollment rather than rely on financial remedies after the fact and so that's very clear again the subtext of the proposed regulations is very clear in shifting the need for evidence from the institutions to students and we see that when we see what the major components of these proposed regulations are there is a new standard that's being proposed for proving intentional misrepresentation by institutions with the emphasis unintentional misrepresentation the proposed regulations prioritize internal arbitration at the institution so students would need to go through the arbitration process at an institution first as opposed to in the prior regulations that the Obama administration propagated that D emphasized institutional arbitration in fact it made it so that students did not have to go through that institutional arbitration which can oftentimes be stacked against students the new proposed the the truck proposed regulations would also restrict the time frame that students could apply for a discharge of loans it removes the departmental authority for group relief and so there would no longer be group relief and instead the department could only look at individual cases which many are concerned would significantly slow down the process for students receiving discharge of their loans because of borrower defense it would remove that automatically loan discharge after three years ability it would also require students to show financial harm and I'll talk a little bit more about that in a sec and this is another sort of huge difference it would make it it would make students ineligible for a discharge if they chose not to participate in an institutional teacher plan so there's a significant shift which I'm sure doesn't come as a surprise to any of us in terms of the deregulation here could you move to the next slide Cheryl so that proposed misrepresentation standard is probably the thing that has gotten the most attention because it's a fairly significant change and these are our and statements not or statements so for a student to be able to claim that an institution has misread itself they would have to show evidence of these three things that there had been a false misleading or deceptive claim that the institution made it knowingly that it was false misleading or deceptive or with a reckless disregard of truth so the student to be able under these new proposed regulations to be able to access for our defense would not only have to show that there was false misleading or deceptive claims but that it was done purposefully by the institution that it was done knowingly so they have to actually show institutional intent which is I think again a sort of significant shift and shifting responsibility for evidentiary claims to the student rather than to the institution and that and again this is sort of critical here and assuming that they are able to show that it was false and misleading or deceptive that those statements were made intentionally a student then has to show that those statements very directly and clearly related to them making a direct loan for employment for enrollment at the institution so in other words the student then applied for enrollment and applied for financial aid on the basis of those statements and it also then says that in order to be considered related to a provision of educational studies misrepresentations must be related to the borrower's program of study so it again it becomes even more specific that not only do any of these statements have to be false and m sleading and intentional and impacted the students decision to enroll but it also has to be very very directly related to the students program of study so if an institution and made these comments and it was not directly related to the to the individuals program of study then they would still not under these meet proposed new regulations students would not be eligible for asking for their loans to be discharged on the base of fraudulent claims and finally a student has to show very specifically the those statements cause them financial harm and again sort of a new evidentiary standard that is being placed on the shoulders of students Cheryl would you go to the next line the other huge shift that these proposed regulations has is that the department is very specifically in its request for comments asking people to talk about whether or not they should continue to allow students to make what are called affirmative claims which is a claim for discharging loans before a student while a student is still in good standing before they have defaulted versus defensive claims and a defensive claim then would be when a student applies to have loans discharged after they have defaulted on those loans and the department seems to be indicating here that they would like to move towards a defensive claim rather than allowing students to make affirmative claims which is the current practice and that has some really huge repercussions it would most likely significantly reduce the amount of the number of students who are able to ask for a discharge of their loans because they would have to default before they could discharge before they could apply for discharge it also would most likely mean that borrowers would have a very brief window to make that application that sort of 1 or 2 month window whenever they are protesting collection proceedings there are concerns that many borrowers might not know that they would be eligible for discharge relief during that period and because that window for making a claim would be so small that they would not have an opportunity to secure legal assistance or other assistance in navigating this process of applying for discharge and again remembering that there's going to be higher evidentiary standards for them under these proposed regulations if they go through than they've had before there's also I think interesting concern that this could significantly impact military members and their families because of security clearance issues if an individual is going to be required to go into default before they can file an application for discharging their loans that will have some impact on the number of individuals who are able to get security clearance or maintain their security clearances right now one of the largest reasons for having security clearances denied has to do with finances and so military students specifically could be harmed under or there's the potential for harm under these proposed regulations it also again because of that requirement to go into default before asking for or applying for discharge it also could disproportionately harm student's employment prospects if they are employing for jobs where credit checks are being run as well as their ability to make large purchases of houses cars anything that would require a credit check and so this is a pretty significant shift now it's important to note that the department doesn't seem wedded yet to this idea of moving only two defensive claims versus currently allowing affirmative or defensive claims it's also I think interesting to note that even organizations like the Heritage Foundation that have historically been in favor of what the department is doing the wall street journal' is another one of those have have said that this idea of only defensive claims may not be a good idea in fact The Wall Street Journal I blew a brand editorial last month where they said you know this idea of moving only towards defensive claims Mars an otherwise reasonable set of proposed regulations I'm sure could you move to the next slide so where do we go from here you've got until August 30th so another two days should you like to make public comments and you've got the I'm assuming Cheryl you'll provide this to folks the Dec afterwards but I've got a link here to the Federal Register which has you know all I believe 250 300 pages of the proposed regulations as well as the information on how to make a public comment there's also sort of three other links here that I think could be interesting reading for folks one is New York Times editorial that was released the other day talking about this idea of our defense and student debt one is article The Chronicle of Higher Ed and this is actually open for everyone it's not one of their paywall articles but there's an article that the Chronicle did last month when these were first promulgated and then a really nice piece at the inside higher ed which also sort of walks through the proposed regulations and gives you sort of a nice Cliff Notes version you want go to the last line Sheryl and so you know I'm happy to take any questions if folks have them you know again I think that we have to see this in a larger context of the direction that the department has been going and seems to continue going and I'm sure as Russ is probably going to talk about you know we're seeing this happen happen with other types of regulations it's also I think is going to be really interesting to see what happens after the midterm elections you know last year I'm not sure that the department was as concerned about higher ed this year there seems to be a little bit more interest in higher ed and again now with a undersecretary for higher ed who's been nominated it'll be interesting to see where things go as well but folks got questions I'm happy to give a shot at answering them we live in interesting times if you all any questions you can either put it in the chat box or just indicate to me that you have a question verbally and we really appreciate you being on the call today to be able to to take us through this this for some of us this is not our normal wheelhouse so to be able to have you break it down for us was really helpful I really appreciate that always happy to help out it's a it's a we live in interesting times right now yes we do yes we do and just to reiterate what van said about the the slide deck I will be posting these as you've noted on our new website everyone has access to the sand coordinator call agenda recording and any other handouts or presentations are all available on the sand website so you have access to that and rust says way to go van yes I echo that so van thanks so much for being on this if people have questions they may contact me and I may be in touch with you I hope you don't mind if we do it that way but people may have questions after they've had a chance to try to to think about this for a little bit so thanks again van and good luck on your meeting today I got to let you go so you can go to your meeting so all right great to have you today guys take care bye bye okay as I was saying to you all earlier we are doing our agenda a little bit different order and next we have Megan Raymond who is the assistant director for programs and sponsorship with WCET to give us a little bit of an overview of the WCET annual meeting you know that the sink meaning is actually held on the Monday and the Tuesday is when the WCET annual meeting will start that so our coordinator meeting can be a ten to four all day and then we'll move on to have a sand gathering after that as noted here so I'm gonna turn this over to Megan talk a little bit about what you know we can see we can look forward to at the WCET annual meeting Megan great thanks so much Cheryl and had I known I was going to be following that tough act I might have asked to be placed later in the agenda it's always tough to follow up behind van but I guess it's better than being behind Russ and Van can you're just glad to have you Megan thrilled to be here thank you can you make me the controller or either bring up the WCET Annual Meeting website and then I can walk through some of the program highlights and I will put the link in this conference will now be recorded okay do I have the powers oh you're going to pull it up there great can everybody see the 2018 annual meeting program Russ says yes so we're going with that okay great and of course inevitably the WCET train just went by alright well hopefully you found much value in what van had to share and that's just a little glimmer into some of the wonderful policy people that we showcase at the WCET annual meeting Russ included and many many others in our community come and share with the attendees what they need to know from a smaller scale at their institution to a broader scale and really how to translate that policy back to your institution so this is just a glance at the agenda hopefully you've been to our website and you've perused it a little bit all you have to do is click on program and it does take a moment to load but then there's some nice features I wanted to walk you through there's this filter option here so if there are speakers that you're really interested in or at times example let's find Russ here then you can simply filter that out and see all of the sessions that Russ is on so this is a great way and you can also just search through and see what topics are interested you and you can begin to build your own agenda and we'll be rolling out the mobile app soon which has a more robust search feature but some of the sessions I really think that you all would be interested in are these ones that Russ is on this one hey my crystal ball is broken includes Russ Kim Solomon who I'm sure you've had some interaction with through the sand group he's an attorney heavily involved with higher ed policy and Liam Matthews who is an accreditor with deaq the distance edge distance education accrediting commission and that'll just be a fun conversation and you'll get to ask many of your own question to them we have a session on accreditation in quality and there's quite a focus this year on accessibility and what that looks like across institutions what are some of the good practices what you should be looking at so those are just a few of the highlights but again I want to encourage you to register for the sand meeting if you haven't already it looks like we only have a handful of the 94 that are here registered so be sure to register for the sand meeting and then plan on staying for the duration of the meeting it's a great opportunity to network with people in all sorts of walks a life in higher ed we have a small group of faculty and instructional designers but a lot of people that are involved in state authorization in distance ed policy and all the gamut so it's a great way to network and connect with people and if I hadn't mentioned it this is our 30th anniversary so it'll also be quite a celebration so I just wanted to step you through some of those processes so that you can really start to create your own agenda but if there are any specific questions please ask and they don't know if Cheryl if you have anything you want to add specific to Sam I just appreciate you being on today I'm not seeing any questions as such oh yes we do have one question Meghan will there be an app yes we are getting ready to roll out the app that'll probably be released close to the earlybird deadline of September 21st and like I said that is the way that you can really start to search and create your own personal agenda so there's add to my agenda that you see on the website here is just connected to your IP address you don't actually have to create an account but with the mobile app you can build a calendar and you can also access the attendee list the official hashtag is WCET 18 another question that was in the chat box great thank you for adding that Meghan and thank you for the question Dave the only other thing that I would like to add for our Sande members is that this is a good opportunity for to learn something new so as I suggested last year and I'm suggesting and this year you're going to want to reach out and do these different sessions because this having this kind of information is important to be able to communicate at your institutions and collaborate with the other departments at your institution so having cursory knowledge of a variety of these higher ed issues is going to be beneficial in the long run Megan I'm going to take back control here I'm not seeing other questions at this point other than Russ included the hash tag which I appreciate so is it going back yet Megan do you see that it's going back okay do you all see can folks tell me if they see the agenda coming back up okay can you all hear me yes okay not yet no okay well I'm gonna keep talking a little bit and we'll wait for it to - okay now they can hear me okay thanks for working with us on this on the technical issues I as we try to get the agenda back up I think I would like to go ahead and thank Megan again for being on today I know you have a meeting as well and so I'm really thankful that you took time out of your day to address our folks because the WCET meeting is so valuable and I hope that people will take advantage of not only the sand coordinator meaning that precedes that the annual meeting but also the annual meeting itself so thanks again to Megan while I'm working on getting this agenda back up I'm going to turn this over I'm very excited about this our new San assistant director went through his orientation two weeks ago we were together in Boulder with Russ and WCET in which he and the NCS era folks and helped Dan get prepared for his new role as Santa assistant director and I would like to turn this over to Santa to Dan to introduce himself tell a little bit about himself and let you all get to know him dan okay thanks everybody I am yes just getting started here as Cheryl's caddy and has had I had a good time with that so far but prior to that I spent three and a half years doing state authorization compliance at a for your public Virginia Commonwealth University and before that I spent five years doing other types of higher education compliance mostly n-c-double-a on a couple of other campuses so I remember really have a lot of respect for the chairs that you were sitting in or the standup desks that you were hovering over and would love to learn as much as I can from you guys and try to really promote San as a as a network the more you guys are learning from each other I think the more successful sand is I think that excuse me a perfect segue over to the summer spotlight so we have our colleagues Dave and Kelly coming to us from Anchorage Alaska to tell us a little bit more about what they are doing great thank you Dan can folks hear us you sound great okay thank you well thank you all for allowing us to say a few words I am Dave Annenberg director of state authorization amongst many other hats here at the University of Alaska Anchorage and I'm joined with my my colleague Kelly like Nick's who is our distance education analyst and focuses on state authorization so I'll I'll start things off just giving you a little bit of the history and then I'll turn it over to Kelly to sort of talk about sort of what she's done over the last few months so the University of Alaska Anchorage is one of three institutions in a in our state part of our statewide university system Alaska was one of the first States to join NC Sara however the University of Alaska Anchorage was the last higher education institution in the state to actually join and it wasn't because we weren't interested it was because our leadership at the time just wasn't sure where state authorization should reside so even though Alaska as a state joined think back in 2015 it wasn't until the fall of last year 2017 that we actually applied and became an NCAA institution during those two years the provost then and who since has become our interim chancellor was hoping to put the authorization process embed that in a couple of other organizations on campus first he looked sort of through some of our faculty governance groups who decreed that they didn't want to do it then he gave it to as a special project to a interim dean of our Honors College and after two years and me telling him multiple times that if he wanted to move forward with NC sera it would have to be something that my department handled and in the larger sense the my team called academic innovations and elearning and we handle all the educational technology professional development instructional design distance student services so it really makes sense for something like Sarah to belong here in the first place so after two years of me telling him that we finally made it happen and as part of that process he also dedicated a half-time position to help me do the sort of the day-to-day fundamental work so beginning last fall one of the first things I did was join this group even before we were an official NCC organization attended the and met many of you at the last last year's I have to get this right last year's workshop in over the summer early September somewhere in there and took everything I had pages and pages and pages of notes and for folks that know me realize I never take notes and had a long to-do list immediately got to work came back we joined NC Sara the Provost then chancellor or interim chancellor gave me a half-time position to help with the work and fortunately after a search we were able to hire Kelly who joined us here in January and Kelly's day-to-day one of the multiple things she does well one of two things she does is handle the the state authorization so building off some of the initial data collection she really got to work and and started laying the foundation of our authorization process and I'll let her say a few words about that yeah it definitely feels like it's been fast and furious since January and a pretty steep learning curve I do not come from a compliance background so there was a little there was quite a learning to sort of navigate through but I will say that one of the things that I found as a as a newbie to this this work is just the the there are a ton of resources available when you look around the website I very much appreciate anytime I have a question I can go to pretty much anyone Russ Cheryl you know my mentor regulators actually have been a fantastic resource for us as we've kind of navigated through once Dave sort of handed this his giant pile of notes over to me the first thing I did was try to just sift through and and put a plan together of how we were going to tackle it you know looking at the data everything from setting up a website researching the state regulations I'm I still feel like we're very much in the infant stage but you know I would say for any new person out there that it really is just step by step take it one day at a time kind of process at least that's what it's been for us um I would I would also well I if anyone has any questions please feel free to pop them into the chat box but I still feel like we're we're you know still sort of navigating through it seems like there's something new every day that that we learn about it yeah I think that we won't make any claim that we're perfect but you know every day we learn something every day we make us like a change every day we're refining our processes moving in the right direction moving in the right direction there yes I can't say we're definitely moving I always think I would guess most of us feel like we're never there yet this group has proved to be proved to be invaluable as we've been on our journey and for that I know we're both very thankful in case you're wondering because we are in Alaska the northernmost state in the country yes we are an actual state we are not a separate country we do refer to the rest of you as being outside or the lower 48 but generally we just say outside no we do not all live in igloos nor do we have snow well depending on where you are you don't have snow on the ground twelve months out of the year we do not ride moose or polar bears we do not all wear tin foil hats to protect ourselves from the radiation of the Sun depending on where you are in Alaska during the summer you can get 24 hours of light just like in the winter you can have 24 hours or three months of darkness here in Anchorage we probably get somewhere in the ballpark of 19 to 20 hours of light in the summer which means yes in the winter we get 19 to 20 hours of darkness the Sun is usually a pro about 4 to 5 hours usually between like 10:00 and 2:00 in the middle of the day but it is even though it's on the horizon it is up it is bright light it's just not directly overhead which all has nothing to do with state offers nothing to do with everything our state right so we're just giving you a little little background on what it's like to be in Alaska well I think that's great I appreciate you sharing that as a former resident of Ontario I kind of understand a little bit about what you're saying about misconceptions so that was that was funny but more importantly what I appreciate that you shared is that it's always a journey we're always moving forward things that we thought we knew were we're correct a couple of years ago we're finding need to be refined and and changed up and you know you've pointed to that directly and I really appreciate that because we're all on that same journey together so we'll continue in that way and that's why we have our network so thanks so much for being on today Dave and Kelly it was really a treat to hear you and hear you talk about your journey at University of Alaska Anchorage thanks very much our pleasure thank you great ok I'm going to turn this over to Russ in just two seconds all I'm going to do because I want to give him the rest of today the rest of our time today I want to point to you on the agenda number 7 thus an advisory group nomination and election process you received on the listserv information about the election for our firsts and advisory group and that inaugural group will come from these 14 nominations if you go on to if you are not are missing the listserv email you can email me a or go to about sand on the website and then on about sand you'll be able to scroll there and see Santa advisory group and it has explanation about the sand advisory group and we'll take you to this link that has not only first the PDF of all of the different nominees and the descriptions about them which I absolutely ask you to read first but also the ballot and then you can submit that ballot that the election will be open until the voting will be open until September 12th so please have a look at that and then also to point out that Tanya spill avoid will be our expert of the month next month to talk to us about open education resources Oh er and so bring your questions for her she is well-versed and can provide a lot of great information to you about state policy and practice for oer and also you'll note here how you can register for the WCT annual meeting and the sand coordinator meeting and now i would like to turn it over to Russ and Russ thank you so much for your patience waiting for your point in this agenda Russ great yeah thank you I guess I could just say hey it's delayed and then go go on from there but maybe I'll say a little bit more about it but this federal state authorization regulation has just been the the weirdest thing around with all the ins and outs that it's gone through in the this cell almost decade that we've been that they've been working working all this and so as you probably know that it was that they announced a delay on July 2nd and then that that date ends up being a problem and I'll talk a little bit about that in a bit but they based upon a letter that we wrote with DIAC and Sarah folks and they also pointed to letter from was AC e that they are saying that they're going to delay it and then really their intent was is that they want to do not enforce it I think because they wanted to make it part of negotiated rulemaking and then I did put in the chat box there that if you're interested looking at it again the blog post that Cheryl I wrote about the negotiated rulemaking and what they were what they're suggesting there and so what negotiated rulemaking is uh if you don't go recall is just that you get people to talk about a particular regulation and figure out and negotiate you know what should that regulation be where should it where should it go and and I served on one in 2014 and Marshalls been on four of them the rulemaking rulemaking PALS very interesting process now for this one they are throwing all sorts of things in there they have 11 items from accreditation core functions of accreditation that's kind of a big thing state authorization rigor and substantive interaction competency-based education with faith-based entities and title title four so just 11 different things and everybody I've talked to things that this is just a poor way to go because we had a negotiated rulemaking that marshal I Ron in 2014 we had six items and to have people who knew about banking and financial aid and state authorization and all these different and one was had to do about testing you know have people who knew about all these different items was very tough and you're constantly getting people up to speed as to what what was going on or they were getting up me up to speed as to what was going on so this isn't a good these are very important topics accreditation is kind of important some of the other credit hours definition that's important and we just don't see how they're going to get you know just a proper hearing or review in in all of this they do have two subcommittees that they're going to work with but we're planning on just there's there's a comment period coming up or there's a comment period them to be ending September 14 we do have information now blog posts we do if you're interested that we welcome you to comment but really at this point we're not really commenting about the substance of the each of the issues they want to know what what they should be negotiating if there's other issues they should add that just blows my mind they've already got too many or I think the thing that we're going to comment on is just what I've said that there's just too much to do this well may just either need multiple rulemaking you know position it in different different role making panels or at least more subcommittees or or something and I think we need to go on I would like to see us go on the record to say that and if any of you you know either if you don't do it officially from your institution that you could do it um you can comment on your own just say that I'm Dave Dannenberg and here's my title and just you can say that your what your title is but just be clear that you're not representing the University because Dave probably likes this job ah so those sorts of things so you can you can you can come and comment on that if you if you wish and so we'll see what happens with that they will probably going to turn this around pretty quickly and we're looking at the actual negotiated you'll be be calling for people to be on whatever panels they put together and we're or we're talking about what we're going to do about nominating people for that and participating in that because we need somebody with the state authorization some of these other issues strong on those issues to be on that panel and maybe you'll be multiple panels who knows and so that will be next we're looking for the time frame to be next spring for for them to hold probably three sessions as typically what they do a lot of issues to get into in two three three sessions with that the other thing that happened with that remember I mentioned that the regulation actually came out July 2nd we have a lawsuit from the National Education Association and California Teachers Association I put a link to an Inside Higher Ed article about that that that came out just recently and that they pointed out that the actual delay was published in the Federal Register on July 2nd and the role went into effect on July 1st which means that the way that they delayed it is probably not the way you're supposed to delay it they were supposed to have had that published prior to July prior to July 1st prior to it going into effect the department is saying that well we had the draft posted on June 30th and that's good F others are saying that that's not good enough and so this will be going to the to the kourt's imagine and if the I was looking through the the brief and it's interesting that Cheryl down specifically and WCT and Richie and San we all get cited in it in terms of supposedly the department said that they just figured out that there was a lot to do in February this year when we wrote letters when they point out that on your behalf that we had written several letters and Cheryl I had testified you know several times in 2017 so it shouldn't have been new to them anyway bottom line they probably have a point they probably didn't follow the right rules in terms of doing this but I keep coming back to that if they want to delay it they could probably view like they did in 2010 and just instead of unique adjustability the enforcement of it that's what they did back then and said instead of delaying the enactment that's a different thing that delayed the enactment or going into effect effective date July 1st they could have missed that that they could still delay the enforcement so I'm curious to see what happens with this lawsuit I'll be curious to see how the department responds I'm not expecting that the courts will say oh this is all in place now and because they would put the institutions in a bad spot to try to figure out oh you're supposed to be complying with something that was put on hold and so so that's a lot of things in a short time and we've only got a few minutes I'll stop to see if anyone has any any questions or Cheryl has any additional comments well I do rust thanks for thanks for all of that but specifically and I think you addressed this in the notice that went out last week what should institutions you know let's let's reiterate what institutions should be doing in light of this that there are other obligations of the institution regardless of the delay correct that's right and that's why always say that there's always the state rules whether there's a federal rule or not that this rules predated them and that you're still expected to follow all those that you if you are assignee onto Sarah then you're expected to follow those rules if you do Department of Defense tuition assistance that they expect you to follow if you're part of that memorandum of understanding and you should know that whether you are or not that they expect you to follow state authorization that they're still if the misrepresentation federal level is going to be watered down but there's lots at the state levels that you should be doing so it's just a sample of things that you still need to be complying with thanks for reiterating that Russ are there any other questions I'm not seeing anything in the chat box yet I know we're getting close to the time and I what I want to ask you here is that if you do have questions please don't hesitate to email Russ or myself we would be glad to respond we covered a lot of material today and all of it will be available on the sand website by the end of the week we'll get this wreck this recorded version up and get it get the transcript up so you will have all of this by the end of the week as an archive to review to be able to see all the information that we shared today Thank You Russ very much for sharing where we are with the federal regulation it seems to change every day when we asked you to do this was prior to the lawsuit coming out so that was yet another aspect that you needed to include and I appreciate that very much so thanks everybody for being with us today as I said we covered a lot of material look forward to talking with you all in September and in the meantime please have a look at the possibility of attending the annual meeting and attending the San coordinator meeting we would enjoy having you have a great day everybody take care you