1. The Tip of the Iceberg

2. More Than State Authorization

3. Living With the (Rest of the) New “Program Integrity” Regulations in an Online Environment Presentation © Dow Lohnes pllc 2011

4. Michael B. Goldstein Practice Leader, Higher Education Dow Lohnes, pllc

6. October 29, 2010 Federal Register Pages 66832 thru 66975 (143 pages)

7. The above cartoon by Peter Steiner has been reproduced from page 61 of July 5, 1993 issue of The New Yorker, (Vol.69 (LXIX) no. 20)only for academic discussion, evaluation, research and complies with the copyright law of the United States as defined and stipulated under Title 17 U. S. Code. On the Internet Nobody Knows You’re a Dog

9. Hour” Credit Hour The “New” Credit Hour

13. The “New” Credit Hour Recognition of Accrediting Agencies: (f) Credit hour policies. The accrediting agency, as part of its review of an institution for initial accreditation or pre-accreditation or renewal of accreditation, must conduct an effective review and evaluation of the reliability and accuracy of the institution's assignment of credit hours. 34 CFR § 602.24

16. Hour” Credit Hour Incentive Compensation

17. Incentive Compensation The institution will not provide any commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments or financial aid to any persons or entities engaged in any student recruiting or admission activities or in making decisions regarding the award of student financial assistance

18. Incentive Compensation The institution will not provide any commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments or financial aid to any persons or entities engaged in any student recruiting or admission activities or in making decisions regarding the award of student financial assistance, except that this paragraph shall not apply to the recruitment of foreign students residing in foreign countries who are not eligible to receive Federal student assistance.

29. Hour” Credit Hour Misrepresentation

34. Misrepresentation

35. Hour” Credit Hour Last Day of Attendance (LDA) The “Sleeper” Issue for Online Programs

41. Hour” Credit Hour Gainful Employment

48. For Further Information Contact us at www.dowlohnes.com/education Or call/email Mike Goldstein 202.776.2569 or [email_address] Blain Butner (incentive compensation) 202.776.2579 or [email_address] Greg Ferenbach (state authorization) 202.776.2792 or [email_address] Ken Salomon (last day of attendance) 202.776.2566 or [email_address]

49. Thank you! Michael B. Goldstein Member of the Firm and Practice Leader Higher Education Dow Lohnes pllc 1200 New Hampshire Ave NW Washington, DC 20036 202.776.2569 [email_address]