DEAC Call for Comment March 2026

DEAC’s Standards Committee, working with the Commission, has undertaken additional revisions to its proposed standards for subscription-based tuition models. After reviewing the comments submitted during the July 2025 Call for Comment period, the Committee refined its earlier proposal to further promote accountability and fairness as institutions adopt more flexible, student-centered approaches to tuition and program delivery.

As presented by the Standards Committee, subscription-based models—typically allowing students to complete as many courses as they can within a set time period for a flat fee—are becoming an increasingly viable approach within distance education delivery systems. Through this proposal, DEAC seeks to promote transparency, protect students, and ensure that academic progress and learning outcomes remain the central focus as institutions implement these innovative tuition models.

The Commission is presenting a revised version of its proposal to include a subscription-based tuition model within Part Four, Appendices, DEAC Accreditation Handbook. Noted revisions to the July 2025 Call for Comment include:

1. Replacing “refund” procedures with “cancellation” procedures.

2. Adding a provision to require a subscription period cancellation policy.

Changes to the original Call for Comment are shown in red font to indicate new revisions, while deletions are marked with strikethrough text.

Appendix XV: Subscription-Based Tuition Model

A Subscription-Based Tuition Model allows institutions to offer a variable amount of educational content to students during a defined period of time, referred to as a subscription period. Under this model, the institution charges students a recurring fee based on the length of the subscription, with the flexibility to accommodate varying amounts of coursework completed during that period. The specific terms related to subscription, renewal, and cancellation must be clearly communicated to students, ensuring transparency and consistency with DEAC’s established standards.

While institutions may adopt the subscription model, it is essential that a refund cancellation policy is implemented in compliance with state requirements or, in the absence of such requirements, in accordance with DEAC’s refund cancellation policy standards ensuring fairness and transparency for students and aligning with the broader principles of equitable financial practices. The following guidelines outline key considerations for the implementation of a subscription-based tuition model.

The institution must establish Subscription Terms and Conditions under which the student elects to participate in the institution’s subscription model, setting the general terms of recurring billing and cancellation.

Active Participation and Inactivity

Institutions utilizing a subscription-based tuition model must clearly define active participation. Active participation may include submission of coursework, completion of assessments, or engagement in other specified academic activities. The institution should ensure that students are informed about these expectations at the time of enrollment.

Institutions are encouraged to establish reasonable criteria to define inactivity, such as failure to submit any coursework or assignments or to engage with the academic platform for a defined period of time.

Reaffirmation of Subscription Periods

To maintain an active subscription, students must periodically reaffirm their subscription. This reaffirmation can be achieved through notifications an opt-in process by acknowledging prior to the start of each new subscription cycle, or at least annually. This process helps ensure that students remain informed of their financial commitments and ongoing participation in the program. The reaffirmation process must be clearly communicated to the student at least once every 12 months.

If the student chooses to pause their subscription, they must submit the request before the end of the current subscription period. Pauses should not exceed a predetermined maximum length (e.g., six months) and should allow the student to resume at the same point they left off upon resumption.

Subscription Period Cancellation Policy

The institution must provide students a cooling-off period of no fewer than five (5) calendar days from the start of each subscription period, during which a full refund of that period’s payment must be granted upon written or electronic notice of cancellation.

Students may cancel their subscription at any time by following the institution’s published cancellation process. Upon cancellation, the student will receive written confirmation. Regardless of when