Developing a State Authorization Policy: It’s About the Journey

Today we welcome Lisa Siefker and Robert Griffiths from The Ohio State University to share their journey to educate their institution, assess practices, create and implement processes that connect the core mission of the university to institutional compliance for out-of-state activities for the entire university. 

The WCET/State Authorization Network (SAN) presents SANsational awards annually to recognize outstanding efforts by SAN member institutions and organizations in developing a high-quality, comprehensive solution to a challenging state authorization issue.  Awards are currently presented in three categories:  Location, Professional Licensure, and Compliance Innovations.  SAN was proud to award The Ohio State University with two 2017 SANsational Awards for:

• Location  (Identification of where students are located).
• Licensure Programs (Notifications and disclosures for professional licensure program status in each state).

Thank you Lisa and Rob for sharing your story of institutional collaboration at a large public university to implement a comprehensive strategy that includes the Out-of-State Educational Activity Policy.  Great work!

–Cheryl Dowd, WCET/SAN

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The Challenge

During the past six years, The Ohio State University has increased its online program offerings from one program to 30. As the number and scope of Ohio State Online programs grew, the university’s Office of Distance Education and eLearning (ODEE) needed a strategy to manage related compliance issues.

In 2013, only three states authorized Ohio State to offer online programs, and the university had no approvals to offer licensure programs — such as nursing — outside Ohio. As the school’s portfolio expanded, most university stakeholders were unaware of state authorization regulations or the regulatory impacts on Ohio State activities. Today, the institution has enacted a university-wide compliance policy, is approved to offer many online programs nationwide, and has established processes to seek and maintain compliance for licensure programs.

Ohio State’s state authorization team faced challenges that are common at many institutions:

• Working with independent academic units.
• Influencing university-wide change without the authority to do so.
• Communicating complex – and continually changing – requirements.

So, how did Ohio State make progress toward compliance? And what key lessons did we learn in the process?

Connecting to the Mission

As ODEE began to develop the university’s compliance strategy, the state authorization team decided not to lead its messaging with the adverse actions and lawsuits that could result from noncompliance. Instead, the team concentrated on the link between compliance and Ohio State’s core mission and values — namely to expand access and affordability and increase student success. Compliance with state authorization regulations ensures that an Ohio State degree will be recognized and that Ohio State students will be eligible to sit for licensure outside Ohio. Therefore, compliance furthers the Ohio State mission.

It’s difficult not to support an initiative that advances the university’s mission and is acutely student focused.

With a communication strategy in place, ODEE began to meet with stakeholders regarding state authorization. The next step was to convert these conversations into action.

Taking Action   

After introducing state authorization considerations to the Office of Academic Affairs, curricular deans, Legal Affairs, the University Registrar, and other university leaders, ODEE invited Russ Poulin, WCET Senior Director, and Cheryl Dowd, WCET State Authorization Network (SAN) Director, to the Ohio State campus to meet with stakeholders. As a state authorization expert who participated in the U.S. Department of Education’s 2014 Negotiated Rulemaking process, Russ was able to share an outside perspective on the national state authorization landscape. His visit gave credibility to the state authorization team’s message.

Although Russ’ visit generated more discussion, stakeholders continued to have questions about state authorization roles, responsibilities, and processes at Ohio State. It was around this time that the idea of developing a university-wide policy began to take shape. Having a policy in place to formalize roles and processes would be nice, but the real value would be in navigating the university policy approval process. The approval process provided a map to reach all university stakeholders and to include them in compliance discussions.

University policies are frequently viewed as enforcement tools. In this case, the state authorization team saw the policy as an opportunity to ensure inclusivity for collectively defining and continually updating the university’s state authorization process to promote compliance, access, and student success. The process also provided an opportunity to lean in to difficult conversations and translate those conversations into the necessary rapport and trust to build meaningful partnerships — the critical element of university-wide state authorization processes.

What’s Next?

The policy approval process took about a year to complete, and the Out-of-State Educational Activities Policy took effect in December 2016. However, having a policy in place doesn’t mean the state authorization team’s work is done. Rather, the policy serves as a starting point for new state authorization conversations and allows for continual updates and refinement through a formal process with our stakeholders.

Now, education and outreach are more important than ever as regulations evolve, new online programs are approved, and new staff join the university.  The team continues to educate the university community on the link between compliance and Ohio State’s core values through a monthly newsletter, regular check-ins, and a faculty and staff state authorization web page. In addition to communicating about state authorization, the team also works to consistently improve compliance and data management processes.

Lessons Learned

Looking back at Ohio State’s compliance progress, we learned  some important key lessons along the way:

• Linking compliance to Ohio State’s core mission helped stakeholders connect to the issue and be motivated to partner in achieving common goals.
• It’s about the journey. The policy approval process was more valuable than the policy itself.
• A successful state authorization team should focus equally on 1) compliance and data management and 2) continual education and outreach.

There is so much more we can learn and achieve as a community when we collaborate and share ideas. We hope this reflection of our journey is useful to you in your work, but we hope this is also the start of a new partnership. Let us know what information and experiences have resonated with you and what actions or strategies you’ve found to be impactful in your college, at your institution, or in your system.

 

 

Lisa Siefker
Program Manager
The Ohio State University

 

Robert Griffiths
Associate Vice President
Office of Distance Education and eLearning
The Ohio State University

 

 

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