ED Expected to Publish State Authorization and Reciprocity Rules This Fall

Published May 14, 2024

By AACOM Government Relations

Advocacy Federal Policy Financial Aid Higher Education OME Advocate

  • The U.S. Department of Education (ED)'s Negotiated Rulemaking Committee on Program Integrity and Institutional Quality recently reviewed state authorization and reciprocity agreements. AACOM nominee Erika Linden, CHC, (DMU-COM) served as the committee’s primary negotiator for private nonprofit higher education institutions.
  • During the negotiations, ED’s final state authorization proposal raised concerns regarding the future of National Council for State Authorization Reciprocity Agreements (NC-SARA) and state reciprocity agreements. Specifically, the “500 rule” would require institutions to obtain direct authorization from any participating state where the institution enrolls more than 500 students in each of the two most recently completed Title IV award years.
  • However, the negotiators failed to reach consensus on state authorization and several other topics. As a result, ED will need to publish its own proposed rule which is expected this fall. Once a proposed rule is released, there will be an opportunity to provide public comment.
  • For more information you can view AACOM’s update and the NC-SARA summary and March webinar. All materials from the Negotiated Rulemaking Committee, including issue papers, proposed regulations and session recordings, can be found on this web page.