Government Affairs

UPCEA Issues Public Comments to Department of ED on Regular + Substantive, Distance Education Regulations

May 1, 2020

Today, UPCEA has submitted comments to the US Department of Education in response to their Notice of Public Rulemaking (NPRM) issued on April 2, 2020, which closes on May 4, 2020. These regulations were informed by the 2018-2019 negotiated rulemaking committee. We wrote regarding clarification and suggested edits for how the NPRM amends key definitions and title IV eligibility requirements for distance and correspondence education providers. UPCEA recognizes the importance of regulating distance education to protect students and the general public. We appreciate the efforts the Department has taken to protect these interests while still encouraging innovation in higher education and student access to affordable, high-quality educational opportunities. 

We generally support the proposed changes contained in this NPRM and believe they advance each of these goals. However, we do seek clarification on several new and amended definitions from the Department as outlined below. The following suggestions and requests for clarification have been submitted both by UPCEA member institutions and by UPCEA’s Policy Committee, and include concerns raised by online program administrators, instructional faculty, and instructional designers:


Click here to read our full comments and suggestions on these issues. 


UPCEA is a proud founding member of advocacy groups such as the Today's Students Coalition as well as the National Adult Learner Coalition.

UPCEA Policy Committee

Ricky LaFosse, University of Michigan, Chair
Kristen Brown, University of Louisville
Allison Friederichs, University of Denver
Mary Niemec, University of Nebraska
Reed Scull, University of Wyoming
Dick Senese, Capella University


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