Distance education is not a new concept, but in recent years, it has assumed markedly new forms and greater prominence. In the past, distance education generally took the form of correspondence courses— home study courses completed by mail. Distance education today can take many forms and is defined by federal law and regulation as education that uses one or more technologies (such as the Internet or audio conferencing) to deliver instruction to students who are separated from the instructor and to support regular and substantive interaction between the students and the instructor. Instruction provided through the Internet—or online—may be synchronous (simultaneous or “real time”) or asynchronous, whereby students and the instructor need not be present and available at the same time (see fig. 1). In general, for their students to be eligible for federal student aid funds under Title IV programs, schools must be legally authorized by a state, accredited by an agency recognized by Education, and be found eligible and certified by Education. State governments, accrediting agencies, and Education form the program integrity triad established by Title IV of the HEA to oversee postsecondary education. The state authorization role is primarily one of providing consumer protection through the state licensing process, while the accrediting agencies are intended to function as a quality assurance mechanism. In certifying a school for participation, Education is responsible for determining the financial responsibility and administrative capability of schools and is also responsible for monitoring to ensure compliance with Title IV requirements. Accrediting agencies, private educational associations set up to review the qualifications of member schools, are the primary overseers of schools’ academic quality. Accreditation is a peer review process that evaluates a school against the accrediting agency’s established standards. An institutional accrediting agency assesses a school in its entirety, including resources, admissions requirements, services offered, and the quality of its degree programs, while a programmatic accrediting agency reviews specific programs or single-purpose schools. A school’s accreditation is re-evaluated every 3 to 10 years, depending on the accrediting agency. If a school makes a substantive change to its educational programs or method of delivery from those that were offered when the agency last evaluated the school, the agency must ensure the change continues to meet standards. Schools may lose accreditation if their accrediting agency determines that they no longer meet the established standards. While Education does not have the authority to dictate the specifics of an agency’s standards, the department recognizes accrediting agencies by reviewing and assessing their standards in various areas required by statute, such as student achievement, curricula, and student support services. Education’s Office of Federal Student Aid (FSA) is responsible for monitoring the over 6,000 postsecondary schools participating in Title IV programs to ensure their compliance with applicable statutory and regulatory provisions and to ensure that only eligible students receive federal student aid. The postsecondary school types include the following:  Public schools—schools operated and funded by state or local governments, including state universities and community colleges.  Private nonprofit schools—schools owned and operated by nonprofit organizations whose net earnings do not benefit any shareholder or individual.  For-profit schools—schools that are privately owned or owned by a publicly traded company and whose net earnings can benefit a shareholder or individual. Education fulfills its school monitoring responsibilities through four main activities. First, it determines the initial eligibility of schools to participate in the federal student aid programs, as well as recertifies that eligibility periodically. Second, as part of ensuring compliance, FSA staff conduct program reviews of a select number of schools each year where they examine school records, interview school staff and students, and review relevant student information, among other things. FSA issues reports on these reviews, which include information on areas where a school was found to be in violation of the Title IV requirements. Third, schools are required to employ independent auditors to conduct annual compliance reviews and financial audits, which are then submitted to Education. Finally, Education’s OIG conducts its own audits and investigations of schools to identify and combat fraud, waste, and abuse and makes recommendations to the department. Education may assess liabilities and/or impose fines or other sanctions on schools found in violation of Title IV requirements. This change was made following Education’s completion of a mandated distance education demonstration project. The project was undertaken to (1) test the quality and viability of expanded distance education programs, (2) provide increased student access to higher education, and (3) determine the specific statutory and regulatory requirements that should be altered to provide greater access to high-quality distance education programs. In 2005, Education reported to Congress that waivers of the 50 percent rule did not lead to increases in fraud and abuse of Title IV funds. 20 U.S.C. § 1009b(c)(2). Recognized accrediting agencies that do not already have distance education within their scope of review may add distance education to their scope by notifying Education in writing. Such agencies must monitor the head count enrollment at each school they accredit, and if any school experiences an increase of 50 percent or more within 1 year, the agency must report that information to Education and also submit a report outlining the circumstances of the increased enrollment and how the agency evaluates the capacity of the school. Education submits that report to NACIQI for consideration in reviewing the agency’s change in scope. 20 U.S.C. §§ 1099b(a)(4)(B)(i)(II) and 1099b(q); 34 C.F.R. §§ 602.19(e), 602.31(d), and 602.34(c)(1). While distance education can use various technologies, it has grown most rapidly online with the use of the Internet to support interaction among users. With the emergence of the Internet and expansion of Internet- based communication technologies, distance education today is a common phenomenon and widely used throughout higher education. Moreover, the term “distance education” no longer connotes only instruction separated by physical distance, since many distance education courses—specifically online courses—are offered to students living on campus as well as away from a campus and across state lines. School offerings in online learning range from individual classes to complete degree programs. Individual courses as well as degree programs may also be a mix of face-to-face and online instruction—often referred to as “hybrid” or “blended” instruction. Furthermore, an online class may be synchronous (simultaneous, real-time instruction), or asynchronous, where students and the instructor are not present and available at the same time. According to a 2008 study on distance education conducted by Education, postsecondary schools of all types offer a variety of distance education courses. Specifically, for the 2006-2007 school year, 61 percent of 2-year and 4-year schools reported offering online courses, 35 percent reported hybrid/blended courses, and 26 percent reported other types of distance courses. The study also suggests that the majority of schools offering distance education used asynchronous Internet technologies. Specifically, 92 percent of the degree-granting postsecondary institutions offering distance education in 2006-2007 reported using asynchronous Internet technologies to a moderate or large extent, compared with 31 percent of schools that reported using synchronous technologies to a moderate or large extent. In our interviews at the schools we selected, officials said that online, asynchronous instruction was also their predominate method for providing distance education and that this type of instruction meets students’ need for flexible schedules. For example, over half of the school officials we interviewed noted that many students taking classes online are working adults or active duty military service members who would otherwise be unable to continue or complete their studies. The use of distance education, particularly online learning, has grown dramatically in recent years. According to a 2010 industry survey, online enrollment in degree-granting postsecondary schools has continued to grow at rates far in excess of the growth for total enrollment in higher education. Survey results indicate that over 5.6 million students were taking at least one online course during the fall 2009 term—an increase of nearly 1 million students over the number reported the previous year and an increase of 21 percent, as compared with the less than 2 percent growth in the overall higher education student population. The survey also suggests that nearly 30 percent of higher education students were taking at least one course online. Such remarkable growth may be attributed to institutional efforts to expand access to more students, alleviate constraints on campus capacity, and the desire to capitalize on emerging market opportunities and compete with other schools. According to Education’s 2008 study on distance education, which includes online and other forms of distance education, the top four factors affecting postsecondary schools’ decisions regarding distance education offerings are (1) meeting student demand for flexible schedules; (2) providing access to college for students who otherwise would not have access due to geographic, family, or work- related reasons; (3) making more courses available; and (4) seeking to increase student enrollment. Several of these factors, such as providing access to more students, were also cited by school officials we interviewed. For example, one school we visited had increased access to education by establishing over 20 “cyber-centers,” including one on a National Guard base and another in a shopping mall where students can access computers with Internet capabilities and participate in online courses as well as complete assignments and take exams. Additionally, officials at two of the schools we interviewed noted that on-campus students were registering for online classes, instead of face-to-face classes that were otherwise full or scheduled for times of day that conflicted with their personal schedules. Furthermore, one school we interviewed provided flexibility to its students by allowing them to begin and complete courses at their own pace. While cost savings might be a factor, none of the school officials we spoke with cited cost savings as the primary reason for providing online distance education courses and programs.