As a Negotiator, Erika Linden Represents Private Nonprofit Higher Education Institutions in Rulemaking Sessions
The U.S. Department of Education appointed Erika Linden, M.A., CHC, chief compliance officer at Des Moines University in West Des Moines, Iowa, to its negotiated rulemaking committee on Program Integrity and Institutional Quality. She was nominated for the position by the American Association of Colleges of Osteopathic Medicine, which advocates for the nation’s 41 accredited colleges of osteopathic medicine in 35 states.
Negotiators on this new committee are discussing proposed regulations that address issues falling under the Higher Education Act, including state authorization and distance education, among other topics. Linden serves as primary negotiator representing private nonprofit institutions of higher education.
Since she joined DMU in 2012, Linden has been responsible for developing, implementing and assessing the university’s compliance program to assure it abides by the relevant rules and regulations that govern higher education, state authorization, distance education, medical school accreditation and clinical practice.
Distance education regulations affect institutions, like DMU, that offer educational programs through virtual, online formats. Those institutions must have approval from other states in order to provide distance education to students residing in those states. Individual state requirements for approval can vary significantly, including in cost and administrative burden. When Linden joined DMU, the university had to determine what each state required and then conform to the process to receive approval to operate. In some cases, the presence of DMU students in other states as they completed clinical rotations was considered distance education for which state approval was required. Linden worked to remove student enrollment and placement barriers by obtaining approval or exemptions in 25 states.
In 2015, the opportunity to achieve authorization though reciprocity between states gained momentum with the establishment of the National Council for State Authorization Reciprocity Agreements. Once reciprocity became a viable means for achieving authorization in other states, DMU became the first Iowa school to become an NC-SARA institution under her guidance.
Today, more than 2,200 institutions have joined SARA in the 49 member states, the District of Columbia, Puerto Rico and the U.S. Virgin Islands.
Since then, Linden has informed other higher education institutions in Iowa about authorization requirements and the importance of reciprocity and has advocated to protect the state’s reciprocity agreements. It’s an ongoing task.
“Current state authorization and distance education regulations cause undue financial and administrative burdens on osteopathic medical schools and students, many of whom complete their clinical rotations out-of-state,” says AACOM President and CEO Robert A. Cain, D.O. “Ms. Linden’s work to obtain and protect reciprocity agreements in Iowa and to educate other institutions about their importance demonstrates her leadership and deep knowledge on this critical issue. She will be an important voice for osteopathic medical schools and students on this vital committee.”
For her part, serving on the committee means Linden has several new, thick folders of material, significant email and telephone correspondence and “hours and hours” of meetings on her calendar. The committee’s first session was held Jan. 8-11, with additional meetings in February and March. She and other negotiators, which represent numerous stakeholders in higher education, will review and comment on regulations proposed by the Department of Education and, in some cases, offer their own proposals to the department. The Department of Education will consider those proposals and recommendations and publish revised regulations with an expected implementation date in July 2025.
“I am honored to serve as a negotiator. My goal is to ‘do no harm’ and avoid regulations that would be detrimental to education programs for future health care professionals,” Linden says. “I appreciate the support from AACOM and their government relations team and look forward to engaging with other colleges of osteopathic medicine as these negotiations move forward.”
