Rhode Island: A Step By Step Guide To Obtain State Approval For A Private Post Secondary Institution

Licensing Agency

Rhode Island Council on Postsecondary Education (CPE) – Office of the Postsecondary Commissioner (OPC). This state agency oversees the authorization of private degree-granting colleges and proprietary (vocational) schools in Rhode Island.

Agency Contact (Degree-Granting)
Rhode Island Office of the Postsecondary Commissioner
Attn: Higher Education Authorization
80 Washington Street, 2nd Floor
Providence, RI 02903
Phone: (401) 736-1100

Agency Contact (Vocational Schools)
Rhode Island Office of the Postsecondary Commissioner
Attn: Proprietary School Licensing Division
80 Washington Street, 2nd Floor
Providence, RI 02903
Phone: (401) 736-1100

Degree-Granting Institutions

Process

Rhode Island law (RIGL §16-40) requires any private college or degree-granting postsecondary institution to secure a Certificate of Approval from the CPE before operating (incorporating or offering courses), unless the institution meets a statutory exemption. Degree-granting institutions (usually non-profit, as for-profit degree colleges are generally not allowed in RI without special statutory authority) must follow a rigorous multi-step approval process:

• Determine Exemption Status — First, confirm whether the institution qualifies for an exemption under Rhode Island law (e.g. long-established institutions, purely online programs under a reciprocity agreement). If exempt, state licensure may not be required (see State Exemptions below). If not exempt, the institution must proceed with the CPE approval process.
  
  
• Accreditation Plan — State regulations mandate that new degree-granting schools pursue accreditation. Institutions offering degrees (associate or higher) must show evidence of initiating contact with the New England Commission of Higher Education (NECHE) about accreditation. purely distance-learning institutions must already hold equivalent regional accreditation. Within five years of starting operations, a degree-granting institution is expected to achieve full NECHE accreditation to obtain permanent (“full”) state approval.
  
  
• Prepare Application Proposal — Compile a comprehensive proposal as outlined by the OPC. This includes a formal request letter from the CEO listing the degrees and programs to be offered and a detailed institutional plan covering governance, academic programs, faculty qualifications, admission policies, student services, facilities, and finances. All supporting documentation must be gathered (see Checklist of Required Items). Because of the scope of review, the proposal should address each criterion in the state’s regulations to demonstrate the institution will meet quality and stability standards.
  
  
• Submit Initial Application — Deliver the completed proposal (unbound original and required number of copies) to the OPC, accompanied by the non-refundable application fee of $1,000 (payable to RIOPC). There is no online submission portal; the application is submitted in hard copy with all exhibits. The OPC recommends filing the application well in advance of any planned start date (several months lead time) to allow for thorough review and scheduling of a CPE vote. Note: If the institution is new to Rhode Island, it must also register with the RI Secretary of State, but the Secretary of State will not finalize incorporation for a postsecondary school until CPE approval is obtained.
  
  
• Review & Evaluation — OPC staff, in consultation with external academic experts as needed, evaluates the application. This review examines the academic content of programs, credentials of faculty, financial viability of the institution, adherence to student consumer protection standards, and alignment with state educational interests. The OPC may organize a review committee or hire external consultants to assess specific aspects (the applicant is responsible for any consultant fees). A site visit to the proposed campus/facility will be arranged to verify that classrooms, labs, library/resources, and safety measures (building, fire code, ADA compliance) are satisfactory. If the OPC finds any deficiencies or missing information, it will notify the applicant to provide clarifications or corrections before proceeding. In some cases, if financial stability is a concern, the institution can be required to post a surety bond (amount determined by OPC) to safeguard student tuition.
  
  
• Council Approval — Once the review is complete, the Commissioner of Postsecondary Education forwards a recommendation to the Council. The CPE must formally vote to approve initial authorization for the institution. Approvals are usually decided at a scheduled public meeting of the Council. Upon CPE approval, the institution is granted Initial Approval to operate, documented by a Certificate of Approval issued by the OPC. Initial approval allows the school to open and enroll students, typically for an initial period of up to one year (and renewable annually up to a maximum of five years while working toward full accreditation). If the Council has reservations about certain conditions, it may grant a shorter conditional approval (e.g. for a few months) with requirements to address specific issues.
  
  
• Initial Operation Period — After receiving initial approval, the institution must operate in accordance with the state’s regulations and any stipulations of approval. During this period (not exceeding five years), the school should be making continuous progress on obtaining accreditation and meeting all state standards. OPC may require periodic progress reports. Note: With limited exceptions, Rhode Island does not authorize for-profit entities to confer degrees, so degree programs are typically offered by non-profit institutions or those with a special legislative charter.
  
  

Application
All application materials for degree-granting authority are submitted to the Office of the Postsecondary Commissioner (usually via mail or hand delivery). The application consists of the formal proposal and supporting documents as outlined by OPC guidelines. The OPC does not currently provide an online application portal for initial institutional approval; instead, institutions communicate directly with OPC staff for guidance and then submit physical copies of their proposal and documentation. It’s important to adhere to the format and content requirements in the regulations to avoid delays (e.g. including the required number of copies and signed forms). The submission should be made at least several months before the desired start of operations, to accommodate the detailed review and scheduling of CPE’s decision.

Fees Payment
Degree-granting institutions must pay a $1,000 application fee when seeking initial approval. This fee is non-refundable and should be in the form of a check or money order payable to the Rhode Island Office of the Postsecondary Commissioner. The payment is submitted along with the application packet. In addition, applicants are responsible for any additional review costs incurred by the state: if the OPC enlists external consultants or conducts extensive site evaluations, the school will be billed for those costs after the review. (OPC will provide an itemized invoice if applicable, and the institution must remit payment for consultant stipends or extraordinary review expenses.) There is no separate “license fee” beyond these costs for degree authorization, and Rhode Island does not charge annual tuition-based fees for degree institutions as some states do. Once the institution moves from initial to full approval, no ongoing annual fee is required, but the school may have to cover costs of periodic evaluations.

Review & Evaluation
The review process for a degree-granting institution is comprehensive. After receiving the application, OPC will first screen for completeness – ensuring all required documents and fee payments are included. A substantive evaluation then follows: the proposal is measured against criteria set in state regulations, including the soundness of academic programs (curriculum rigor, credit hours, learning outcomes), faculty qualifications (degrees, experience appropriate for the courses to be taught), student support services (academic advising, library access, facilities), and the institution’s governance and administrative capacity. Financial review is critical: the school must demonstrate adequate financial resources and planning to sustain operations; audited financial statements and projections will be analyzed. If the institution is not yet accredited, the OPC will verify that an accreditation roadmap is in place (such as a candidacy plan with NECHE) and that the school understands it must achieve accreditation within the allowed timeframe. External experts may be asked to review academic sections of the proposal, especially for new degree programs, to ensure they meet collegiate standards. The OPC staff may conduct interviews or meetings with institutional representatives during this phase, and as noted, will physically inspect the campus site for compliance with health, safety, and accessibility requirements. Any shortcomings identified must be remedied or explained to the Council’s satisfaction before approval is granted.

Additional Review
Unlike some states, Rhode Island’s approval process for private institutions is centralized under the Council on Postsecondary Education, so there is no separate higher education commission or board that duplicates this process. However, there are a few additional steps or cross-agency considerations to note:

• Secretary of State Filing – New degree-granting institutions intending to incorporate in Rhode Island must coordinate with the RI Secretary of State’s Business Services. The Secretary of State will require a certificate of approval from the CPE before finalizing the incorporation or authorizing the entity to legally transact business as an educational institution. Applicants often submit incorporation documents in parallel, but final incorporation is contingent on Council approval.
  
  
• Accrediting Agencies – As part of the state requirements, the institution must engage with an accrediting body (NECHE for academic degrees). While not a state “agency,” this step is effectively an external review that runs concurrently: the institution will be working to meet accreditor standards even as it meets state standards. Evidence of maintaining progress (such as achieving candidacy status) may be requested during annual updates.
  
  
• Professional Licensing Boards – If the proposed institution will offer programs that lead to professional licensure (for example, a nursing program or teacher preparation program), the institution may also need approval from the relevant Rhode Island professional board or agency (e.g. Board of Nursing, Department of Education for teacher prep). This is separate from institutional approval: typically, program-specific approval is sought after the institution itself is authorized. The OPC will often require disclosure of such programs and may coordinate to ensure the institution is aware of those obligations.
  Overall, the primary approval comes from the CPE; additional reviews are situational and program-specific rather than an extra layer for institutional authority.
  
  

Licensure Decision
The final decision on licensure (authorization) is made by the Council on Postsecondary Education at one of its meetings. If approved, the OPC will issue a formal Certificate of Approval to the institution. This certificate (or approval letter) will outline any conditions of approval and the effective dates. Initial approval for a degree-granting institution is typically granted for a limited period (up to one year at a time, renewable annually) until the institution satisfies all criteria for full approval. In practice, Rhode Island grants initial authorizations that are renewed each year while the institution works toward accreditation; the institution must apply for full approval before the end of the fifth year. Full approval is the equivalent of a permanent license to operate: once an institution attains full approval, its authorization remains in effect indefinitely for non-profit institutions, subject to ongoing compliance (for-profit institutions, if ever applicable, might be given fixed terms). The OPC will send written notification of the Council’s decision to the school. If the decision is a denial, the notice will include reasons and usually an opportunity to remedy and reapply or an appeals process. In cases where the Council or Commissioner had serious concerns but not enough to outright deny, a conditional approval may be issued – for example, granting six months of authority with the requirement that certain issues (financial guarantees, curriculum improvements, etc.) be fixed during that time. A conditional or provisional approval allows a school to operate on a short leash; the institution would have to come back to the Council for full approval once conditions are met. Once a full approval is granted (typically after the institution becomes accredited and has demonstrated stability), the Council’s oversight becomes more periodic (rather than annual reauthorization). The Certificate of Approval (initial or full) is the key document – it must be displayed or available as evidence of legal authority to operate.

Continuous Compliance
After obtaining state approval, degree-granting institutions must maintain compliance with all applicable laws and the standards under which they were approved. There is no routine annual license renewal for fully approved degree institutions, but the OPC and Council retain oversight authority. Schools are expected to operate strictly within the terms of their approval: for instance, they may only offer the degree programs that were approved (any new degree programs or major changes in location or ownership require advance approval from the Council). Institutions must remain in good standing financially and academically. If an institution loses its accreditation or fails to achieve accreditation within the prescribed timeline, its state approval can be revoked or not advanced to full status. Regular reporting may be required (such as submitting annual audited financial statements or enrollment data to the OPC). The OPC also may conduct periodic evaluations or site visits even after full approval, especially if concerns arise about quality or stability. All advertising and recruitment must be truthful and not misleading; Rhode Island regulations prohibit false representation, so institutions should have OPC review any substantive new advertising or marketing materials if needed. Student consumer protection is an ongoing responsibility: schools must adhere to state rules on tuition refund policies, maintain student records securely, and have a teach-out plan ready in case of closure (to allow students to finish their education elsewhere or get refunds). If the institution plans any significant changes (e.g., adding a new degree program, changing its name, merging with another entity), it must notify and seek approval from the OPC/Council beforehand. Continuous compliance is monitored and enforced by the OPC, and the Council can impose actions (probation, conditional status, or revocation of license) for non-compliance. In summary, even after the initial hurdle of licensure, schools have an ongoing duty to meet state standards in their day-to-day operations.

Renewal
For degree-granting institutions, “renewal” in the context of moving from initial to full approval is a one-time milestone rather than a recurring license renewal. Initial approvals are time-limited and must be renewed (replaced by full approval) usually by the end of five years. An institution operating under initial approval should apply for full approval as soon as it meets all criteria (primarily, obtaining accreditation). The full approval application will involve submitting an updated proposal demonstrating compliance with all standards and proof of accreditation status. This application for full approval should be submitted about 6 months before the initial approval period expires to allow the Council to review and act. Once the Council grants full approval, the institution does not need to reapply annually; the approval remains valid as long as the institution continues to comply with state regulations. However, if the institution fails to achieve accreditation within the allowed timeframe, the Council may grant a renewed conditional approval or extension if significant progress is being made, or it may let the authorization lapse. In practice, the OPC works closely with new institutions approaching the end of initial term to facilitate a smooth transition to full approval if warranted. After full approval, there is no set renewal interval – the Council, through OPC, will monitor the institution and may require an evaluation or report at its discretion (for example, a periodic review every 5 or 10 years, or if a major concern arises). Institutions should be aware that any lapse in accreditation, financial solvency, or legal authority (such as loss of corporate good standing) can trigger a review or potential revocation of state approval even after full licensure. In summary, degree authorization renewal is mainly about achieving full approval; once that is secured, maintaining compliance substitutes for a formal renewal process.

Checklist of Required Items (Degree-Granting)

When applying for initial approval to operate a degree-granting institution, be prepared to provide a thorough set of documentation to the OPC:

• Letter of Intent: A cover letter from the chief executive (President or CEO) formally requesting authorization to operate, listing all proposed degree programs and levels to be offered.
  
  
• Charter & Governance Documents: Proof of incorporation or charter (or draft articles if new), governance structure details, bylaws, and a list of principal officers/trustees of the institution. Include any conflict-of-interest policies for the board or management.
  
  
• Institutional Proposal: A comprehensive narrative addressing state review criteria (often organized by sections such as mission, governance, academic programs, admissions policies, faculty, student services, library/resources, facilities, finances, evaluation/assessment plans, and integrity). This is essentially the main application document that should follow the outline provided in state regulations.
  
  
• Academic Catalogs and Policies: Draft catalogs or student handbook detailing the programs to be offered, curriculum requirements for each degree, academic rules and policies, grading, admissions standards, etc. Also include sample advertisements or promotional materials the school plans to use.
  
  
• Curricula and Course Outlines: For each proposed program of study, provide course descriptions, credit hours, program length, and learning outcomes. If the institution plans any certificate programs above the associate level (post-associate certificates), include those as well (note: certificate programs below the associate level would fall under proprietary school rules).
  
  
• Faculty Qualifications: A list of prospective faculty and administrators, with resumes/CVs and academic credentials for each. The state will expect that instructors teaching college-level courses have appropriate degrees (typically at least a master’s in the field for undergraduate teaching, etc.) and experience. Also outline the hiring criteria and faculty policies (teaching load, evaluation, etc.).
  
  
• Facilities Plan: Information on the physical location: campus address, descriptions of classrooms, labs, libraries, and major equipment. Provide copies of any campus lease or deed, floor plans if available, and evidence that the facility will meet safety codes – for example, a fire marshal’s certificate and building inspection approval, plus accessibility compliance (ADA). If the institution will operate in an existing educational facility, include that context; if building new, provide timelines and permitting status.
  
  
• Financial Statements: Evidence of financial soundness to launch and sustain the institution. Submit audited financial statements (or for new entities, audited statements of parent organization or founders, if available) and detailed financial projections for at least the first three years. Projections should include anticipated tuition revenue, operating expenses, staffing costs, and contingency funding. If owners or a corporation are backing the school, include personal or corporate financial statements to demonstrate backing.
  
  
• Surety Bond (if required): While not automatically required for degree institutions, the Council can require a bond (with a surety company) if financial stability is in question. Be prepared to obtain a bond (or letter of credit) if OPC advises one; bond forms and amounts would be determined in consultation with OPC (for proprietary schools, a bond is mandatory – see below).
  
  
• Accreditation Correspondence: Documentation showing compliance with the accreditation-initiation requirement: e.g. a copy of communication with NECHE initiating the accreditation process, any response or guidance from NECHE, and the institution’s timeline and plan for achieving candidacy and full accreditation. If the institution is already accredited elsewhere or by another recognized accreditor, include proof of that accreditation.
  
  
• Student Support and Records: Describe plans for student services (advising, career services) and provide sample student forms such as enrollment agreements, if any are used. Also include a teach-out plan outlining how students will be protected and assisted to complete their education if the institution were to close or lose approval (including an arrangement for transfer of academic records to another repository).
  
  
• Compliance Statements: Sign and include any required affidavits, such as an anti-discrimination compliance statement affirming the school will not discriminate and will adhere to equal opportunity laws. Also include any other affidavits the OPC requires (for example, statements regarding truthfulness of the application).
  
  
• Fee Payment Proof: Attach a copy of the check or receipt for the application fee ($1,000) and any other fee payments required.
  
  

This checklist is not exhaustive – the OPC may request additional information during the review. It is crucial to follow the official “Regulations Governing Institutions of Higher Education (A-5)” and any application guidelines provided by OPC to ensure all necessary items are included.

Fees & Timelines (Degree-Granting)
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Vocational and Career Schools

(Non-degree postsecondary schools offering occupational, trade, or technical programs)

Process

Private postsecondary schools that offer career training, trade certificates, or other non-degree credentials (and no degree programs) are regulated as proprietary schools in Rhode Island. These schools also require state approval to operate, in the form of an annually renewed Certificate of Approval from the Council on Postsecondary Education. The process shares similarities with degree-college licensure but with some differences tailored to vocational programs:

• Pre-Application (Financial Assessment) — Before a new proprietary school can formally apply, it must undergo a pre-application financial review by the OPC. The school’s owners submit financial information (such as business plans, projected budgets, proof of startup funding, and personal financial statements of owners) for OPC to evaluate the financial soundness of the proposal. The OPC will notify the applicant if the financial base appears sufficient to proceed. Pre-application authorization from OPC is required and, once granted, is valid for one year (the school must apply for initial approval within that time).
  
  
• Initial Application — After clearing the financial pre-check, the school prepares the full application for initial approval. This includes completing the official proprietary school application form and assembling all required documentation (see Checklist of Required Items below). The application must be submitted at least six months before the intended start of operations. A non-refundable $2,000 application fee payable to RIOPC must accompany the submission. OPC will only review the application when it is complete – incomplete packets will be returned or delayed, so schools should ensure every required item and attachment is included.
  
  
• Staff Review & Site Visit — OPC staff, using the criteria in the Regulations Governing Proprietary Schools (A-6), will review the application materials. They verify that the school’s programs, policies, facilities, and personnel meet state standards for quality and student protection. A key part of this review is an on-site inspection: OPC will schedule a site visit to examine the school’s facilities and equipment. During the visit, officials check that classrooms or training spaces are adequate, safety codes are met (fire extinguishers, exits, building occupancy limits, ADA accessibility), and that the location matches the details provided in the application. If certain specialized programs are offered (like cosmetology, massage therapy, etc.), those facilities may require additional inspection or certification from the relevant state agency (e.g. Department of Health for massage therapy classrooms). The OPC review may also involve external consultants for evaluating specific technical programs, and the school would be responsible for paying any consultant fees (OPC will consult the school beforehand if such external review is needed).
  
  
• Bond Determination — As part of the initial application review, the Commissioner will determine the required surety bond amount for the school. Rhode Island mandates that proprietary schools post a bond (or equivalent security) to protect students’ prepaid tuition. The minimum bond is $10,000, but the actual required amount is based on the formula involving the school’s maximum unearned tuition liability (often linked to peak tuition collected for programs not yet delivered). The school must obtain a bond from a licensed surety company (or an approved letter of credit if a bond is not obtainable) in the specified amount. Proof of this bond must be submitted to OPC before final approval can be granted. (The bond must name the RI Council on Postsecondary Education as beneficiary, to be used for refunds to students if the school closes or fails to fulfill its contracts.)
  
  
• Council Decision — Once OPC staff review is complete (including receipt of an acceptable bond and resolution of any application deficiencies), the Commissioner of Postsecondary Education will make a recommendation and forward the application to the Council on Postsecondary Education for action. The CPE will vote on whether to approve the school at a regular meeting. If approved, the school is granted an initial Certificate of Approval to operate as a proprietary school. Initial approval allows the school to begin enrolling students and offering instruction legally. Initial approvals are generally effective for the remainder of the academic year cycle and expire on August 31. (For example, a school approved in April would need to renew by the upcoming August 31.) If the Council or Commissioner has concerns, they may choose to grant a conditional approval for less than a year, giving the school a chance to start operations under close monitoring and correct any issues by a specified deadline. If the application is denied, the school cannot operate; it would have to address the reasons for denial and reapply if it wishes to pursue approval later.
  
  
• Annual Renewal — Unlike degree-granting institutions, proprietary career schools must renew their approval every year. Approval to operate is not ongoing without renewal – it is explicitly tied to the annual period of September 1 through August 31. Therefore, a newly approved school will need to submit a renewal application in the summer before the next September to continue operating (details in Renewal section below). Schools operating without a valid (current) approval are subject to penalties, including potential civil or criminal prosecution. Rhode Island is strict about unauthorized operation, so maintaining timely renewal is crucial.
  
  

Application
The proprietary school application process is managed by the OPC’s Workforce/Proprietary School unit. Application forms (for both initial approval and renewal) are provided by OPC, often available on the OPC website or by request. The initial application, along with all required exhibits, must be submitted in hard copy to the OPC at the Providence office address. There is no online submission portal for proprietary school licensing at this time. Schools should fill out the application form completely and have an authorized owner or officer sign where required (certain forms need notarization, such as the anti-discrimination compliance statement). All supporting documents (catalogs, policies, financial statements, etc.) should be clearly labeled and organized as per the checklist instructions. It’s wise to use the provided checklist as a cover sheet to ensure nothing is missed. The OPC encourages applicants to engage in informal consultation with OPC staff while preparing the application – you can reach out with questions or to review any specific requirements before formally submitting. Once ready, the full packet and fee payment are delivered to OPC. Keep copies of everything submitted for your records. After submission, OPC will correspond with the school’s designated contact (often the school owner or director) regarding any additional needs or the status of the review.

Fees Payment
Fee requirements for career schools are straightforward: an initial application fee and an annual renewal fee. For initial approval, the school must include a payment of $2,000 with its application. This fee is non-refundable, even if approval is denied or if the application is withdrawn. It covers the cost of processing and reviewing the application. The payment should be made via check or money order to “Rhode Island Office of the Postsecondary Commissioner.” In the event that the review involves external consultants, there may be additional costs as noted; those are not collected upfront but rather invoiced to the school after the review. For annual renewals, each year the school must pay a $200 renewal fee along with the renewal application (by July 31). Late submissions can jeopardize the school’s continuous approval, so budgeting for and sending the renewal fee on time is critical. Aside from these fees paid to the OPC, a proprietary school should also account for the cost of obtaining the required surety bond. The bond will have its own premium (paid to the surety company) which depends on the bond amount and the creditworthiness of the school/owners. That bond cost is not paid to the state but is a condition of approval. All state fees are subject to change by the Council, but as of current regulations the $2,000 and $200 figures are in effect. There are typically no other state-imposed fees unless the school chooses to seek additional approvals or exemptions.

Review & Evaluation
OPC’s evaluation of a proprietary school application focuses on ensuring the school will provide quality instruction and fair business practices to students. Major areas of review include:

• Program Quality and Relevance: The proposed curricula for each program are examined to see that they align with the occupation or trade they purport to train for. Program outlines should show appropriate sequence of topics, sufficient instructional hours, and clearly stated skills or competencies students will gain. OPC looks for evidence that the programs are not misrepresented – for example, a “Medical Assistant” program should cover the necessary clinical and administrative skills, and meet any industry standards or licensing prerequisites. For vocational schools, hands-on training is critical: the review checks that facilities and equipment are adequate (e.g. for an HVAC repair program, are there sufficient tools and training units; for a cosmetology program, are there enough workstations, etc.).
  
  
• Instructor Qualifications: The school must demonstrate that its instructional staff are qualified in the fields they will teach. Typically instructors should have substantial work experience and/or certification in the trade (academic degrees are less emphasized than industry credentials for purely vocational content, but some fields may require degrees). OPC will review resumes and may verify any professional licenses (for example, an electrical trade instructor should hold an electrician’s license). Having qualified instructors is a must; if the OPC finds instructors lack appropriate background, the school may need to hire additional faculty as a condition of approval.
  
  
• Facility and Health/Safety Compliance: The OPC evaluation includes ensuring the physical location is safe and conducive to learning. The required pre-opening inspections by fire marshals and building officials must show the site is up to code. For schools in certain fields, the Department of Health’s approval (as for cosmetology or massage schools) must be obtained. The OPC will not approve a school that poses health or safety risks to students. Additionally, the school should be accessible to individuals with disabilities (compliance with the Americans with Disabilities Act). If a site visit uncovers deficiencies (e.g. inadequate ventilation in a welding workshop, or missing emergency exits), those must be fixed before approval.
  
  
• Financial and Administrative Capacity: Even though a business plan was reviewed in pre-application, OPC will confirm that the school has the resources to operate at least for the first year. There should be evidence of working capital to pay instructors, rent, equipment, etc., even if student enrollment is initially low. The school’s refund policy is scrutinized to ensure it complies with state mandates (students who withdraw should get fair refunds per state formula). The required surety bond amount, calculated based on projected tuition collections, provides a safety net; OPC verifies the bond is in place. The school’s ownership and management are also considered – OPC must be confident that the individuals in charge are responsible and ethical. That’s one reason reference letters and background info are required, to flag any past fraudulent educational ventures or criminal issues.
  
  
• Student Consumer Protections: OPC will review the catalogs and enrollment agreements to ensure that students are treated fairly. All advertised claims (job placement rates, salary expectations, certification outcomes) should be truthful and substantiated. The enrollment agreement should include cancellation and refund terms, and not contain abusive clauses. Additionally, if the program prepares students for a state license (like a cosmetology license exam), the curriculum should meet state training hour requirements for that license – OPC coordinates with licensing boards to confirm this alignment. Schools are expected to clearly disclose all costs (tuition, fees, supplies) to students upfront, so OPC checks the schedule of tuition and fees for completeness.
  
  
• Accreditation (if applicable): Most vocational schools in Rhode Island are not required to be accredited, and accreditation is not a precondition for licensure. However, if a proprietary school already has accreditation by a national career school accreditor or plans to seek it, OPC takes note. (Accreditation is only mandatory if the school later decides to offer degree programs.) Accredited schools might be streamlined in some oversight aspects, but initially they must still meet all state requirements independently.
  
  

Throughout the review, OPC may communicate with the school for clarifications. The process is somewhat iterative – OPC might send a letter outlining needed additional information or adjustments (for example, “provide a more detailed course syllabus for X program” or “the fire inspection report is missing, please submit”). The school should respond promptly to any such requests to keep the approval timeline on track. Only after OPC is satisfied that all regulatory standards are met will the application be forwarded for final Council approval.

Additional Review
Proprietary schools sometimes intersect with other regulatory frameworks. Rhode Island has carved out certain areas where another agency’s approval might exempt a program or, conversely, be a prerequisite in addition to OPC approval:

• Schools Under Other Agency Jurisdiction – If a program or school is already overseen by a different state entity, it may not fall under CPE/OPC oversight. For example, driver training schools are licensed by the RI Division of Motor Vehicles; a driving school would not need a CPE certificate (and is explicitly listed as exempt from CPE regulations). Similarly, flight schools with FAA certification do not require separate state approval to offer pilot training. OPC maintains an exemption list (see State Exemptions) for these cases.
  
  
• Healthcare-Related Training – Programs such as EMT training courses are approved by the Department of Health (RIDOH) and do not require CPE approval if they are solely to meet professional licensing requirements. If a proprietary school intends to offer such courses as part of its catalog, it should coordinate with RIDOH. Hospital-based training programs (non-profit hospitals offering community health courses) can often operate without CPE approval as well, provided they are accredited by appropriate medical accrediting agencies.
  
  
• Cosmetology and Massage Schools – These fall under OPC oversight as proprietary schools, and they have additional requirements: cosmetology, barber, esthetician, or massage programs must meet curriculum and facility standards set by the Department of Health or relevant boards. OPC will not give final approval until the school shows evidence of inspection and compliance with those boards. Essentially, the school needs dual approvals: one from the Council (OPC) and one from the professional board. Coordination is key – the school should contact the Dept. of Health’s professional licensing division early to schedule any required inspections (for example, cosmetology schools are inspected for sanitation and space requirements annually by RIDOH).
  
  
• Apprenticeship and Trade Licensing – Some trades (electrical, plumbing, etc.) may have apprenticeship programs regulated by the Department of Labor and Training (DLT) or specific trade boards. If the proprietary school is offering a program in a trade that feeds into a state apprenticeship or licensing pathway, the curriculum may need DLT approval to count toward apprenticeship hours. This isn’t a separate “license” for the school, but failing to align with those requirements would disadvantage students. OPC may consult DLT or advise the school to ensure their program meets any such criteria.
  
  
• Veterans Training Approval – If the school intends to enroll students using GI Bill benefits, an additional approval from the State Approving Agency (a federal/state function for veterans education) is needed. This is outside of OPC’s process but is something to be aware of post-licensure. OPC’s approval is a prerequisite for VA approval.
  
  

In summary, OPC works as the primary regulator for proprietary schools, but schools must also comply with any other applicable state regulations in their field. Many of these cross-overs are handled through the exemptions list (where a program might not need OPC license at all if another agency covers it). When in doubt, OPC can clarify whether a given program requires Council approval or falls under an exemption.

Licensure Decision
After the Council votes, the OPC will issue a written decision to the applicant school. If approved, the school receives a Certificate of Approval indicating it is authorized to operate as a private proprietary school in Rhode Island. This certificate will typically specify the school name, location, and the approval period (e.g. “valid through August 31, 2025”). The initial approval is usually valid until the end of the current approval year. All approvals then expire on August 31 and must be renewed effective September 1 annually. If the Council instead grants a conditional approval (due to some reservations), the notification will outline the conditions (for example, “Approved for a six-month period ending [date], during which the school must limit enrollment to X students and submit quarterly financial reports” or other such conditions). The school must meet these terms to be considered for an extension or full-year approval. If the application is denied, OPC’s notice will explain the reasons and typically inform the owners that the school is not permitted to operate. Operating without approval or after a denial is illegal – the Council has authority to seek injunctions and fines, and even criminal penalties can apply for willful violations. A denied school may choose to remedy deficiencies and reapply in the future, but only after addressing the issues cited. Once a school is approved, the OPC keeps that school on its roster and will send renewal reminders each year. The actual licensure decision is formalized in the Council’s meeting minutes as well. Schools should keep their approval certificate on file (and some choose to display it at their school). Importantly, students and the public may inquire with OPC to verify if a school is legitimately licensed – thus, having that up-to-date approval is critical for credibility as well as legality.

Continuous Compliance
Proprietary schools must continuously adhere to the Standards of Operation set forth in state regulations. Key ongoing responsibilities include:

• Maintain Bond and Insurance: The school must keep its surety bond active at all times. Proof of bond continuation is required at each renewal. Lapsing or canceling the bond can lead to an immediate cease-operation order. Additionally, any liability insurance (if applicable for student clinics, etc.) should be maintained for safety.
  
  
• Observe Approved Operations: The school should only offer the programs and use the instructional sites that have been approved. If the school wants to introduce a new program or open an additional location, it must seek OPC approval beforehand (via an application for program amendment or new location approval, potentially requiring another site inspection). Similarly, substantive changes in ownership or school name require notifying OPC and obtaining approval.
  
  
• Update Catalogs & Contracts: The content of student-facing documents like the school catalog and enrollment agreement must remain current and compliant. If the school needs to change a policy (attendance policy, grading, etc.) or tuition rates, those changes must be submitted to OPC (often OPC requires approval of catalog changes prior to distribution). All advertising and marketing materials must remain truthful; the school is expected to submit new advertisements or significant website changes to OPC at least concurrently with their public release so OPC can monitor for any misleading claims.
  
  
• Student Records and Outcomes: The school is required to keep accurate student records (transcripts, enrollment agreements, financial ledgers) and to have a secure plan for records storage. Each year the school will report data on student enrollment, completions, licensure exam pass rates (if applicable), and job placement rates. These outcomes are monitored as part of renewal to ensure the school is delivering on its promises. Very low pass or placement rates might trigger additional scrutiny; the school should strive to maintain acceptable outcomes in the vocational context.
  
  
• Faculty and Facility Compliance: The school must ensure instructors remain qualified (any new hires should have appropriate credentials which may need to be submitted to OPC with the renewal). Facilities must be kept up to code – annual fire inspections are typically required, and cosmetology/barber schools need an annual health inspection. The school should schedule these inspections in a timely manner (coordinating with local fire authorities and health department) and include updated certificates in the renewal package.
  
  
• Ethical Business Practices: Rhode Island regulations forbid proprietary schools from engaging in fraudulent or deceptive practices. Schools should not pressure students into contracts, and must adhere to the posted refund policy when students withdraw. The OPC provides oversight and will investigate complaints from students. Continuous compliance means promptly addressing any student complaints or concerns brought to the OPC. In the event of serious violations (like operating a program that was not approved, or failing to refund students as required), the Council can take enforcement action including suspension or revocation of the school’s approval.
  
  
• Teach-Out and Closure Preparedness: The school should keep its closure plan current. If any signs point to financial instability (e.g., sudden drop in enrollment revenue), the school should inform OPC proactively. In a worst-case scenario of impending closure, the school is obligated to work with OPC on an orderly teach-out or transfer of students, and ensure refunds are made. The bond could be used to cover refunds, but the school must still follow the proper process.
  
  

By staying in compliance year-round and communicating any changes to OPC, schools can avoid jeopardizing their approval. Essentially, the initial licensing isn’t the end – the school enters an ongoing regulatory relationship with OPC to ensure quality and consumer protection are maintained every year.

Renewal
Every proprietary school must renew its approval annually to continue operations legally. Renewal applications are due by July 31 each year, ahead of the September 1 start of the new approval year. The OPC typically sends a reminder or renewal packet, but it is ultimately the school’s responsibility to submit on time. The renewal process involves:

1. Renewal Application Form – Complete the official renewal form provided by OPC. This form updates basic information on the school (name, address, contact person, type of ownership, etc.) and includes a certification that the information submitted is accurate. An authorized owner or director must sign it (often with notarization).
   
   
2. Updated Documentation – Along with the form, the school must attach various updated documents for OPC review:
   
   
   
   • Financial Statements: Current audited financial statements for the most recent fiscal year, with a notarized statement from the owner attesting to their truthfulness. (Note: If the fiscal year has just ended and the audit is not ready by July 31, OPC allows the audit to be submitted within 120 days of fiscal year end, but some financial information might still be required with renewal.)
     
     
   • Bond Continuation: Proof that the surety bond is in effect for the upcoming year (a bond renewal confirmation from the surety or a continuation certificate). The bond amount will be re-evaluated if the school’s enrollment or finances have significantly changed; if needed, the bond might have to be increased.
     
     
   • Inspections: Current safety certificates, specifically an annual fire marshal inspection and building code compliance certificate. For cosmetology or similar schools, an up-to-date health department inspection report. These certifications ensure the facility remains safe each year.
     
     
   • Academic Calendar: An updated calendar for the new academic year (showing term start/end dates, holidays, etc.).
     
     
   • Student Outcomes Data: A summary of program enrollments and completions for the past year (usually broken down by program), the most recent pass rates for any license exams that graduates are expected to take, and job placement rates for graduates (if tracked). If a program had no graduates yet or is new, that can be noted with “N/A” or zero as applicable. Accredited schools might have this data through their accreditor, but it must be submitted to OPC as well.
     
     
   • Accreditation Status: If the school has obtained accreditation or any approvals from other agencies during the year, provide evidence. If not, a simple statement of any progress or that the school remains unaccredited is required. (While accreditation is not required for vocational schools, OPC keeps this on record, and it’s critical if the school plans to pursue degrees in the future.)
     
     
   • Current Enrollment Agreement: A copy of the student enrollment contract currently in use (for each program if they differ). OPC checks that it still contains required refund language and no prohibited clauses.
     
     
   • Current School Catalog: A copy of the latest catalog or student handbook. The school must certify on the cover (or via a statement) that “this catalog is true and correct in content and policy” and have it signed and dated by a school official. This ensures OPC has the latest version of all policies.
     
     
   • Teach-Out Plan: An updated closure/teach-out plan, signed and dated, reaffirming how students would be protected if the school closes. (Even if unchanged from last year, it often must be re-submitted and signed anew to confirm it’s still accurate.)
     
     
   • Personnel and Equipment Update: An updated list of instructors and their credentials (to capture any new hires or staff changes) and an updated inventory list of major instructional equipment, textbooks, and supplies used in programs (showing that the school continues to have the necessary resources).
     
     
   • Other Items: Any additional material the Commissioner requests. This could include tax returns of the owners if there’s concern about financial stability, or explanations for any irregularities noted during the year.
     
     
3. Renewal Fee – Include the $200 renewal fee (check or money order to RIOPC). The fee is required each year and is non-refundable.
   
   

OPC will review the renewal application similarly to an initial application, but usually more straightforward since it’s updating information. If something is missing or if there are compliance concerns, OPC may correspond with the school or even convene a meeting. The Commissioner of Postsecondary Education has the authority to approve routine renewals on behalf of the Council, meaning most renewals do not need a formal Council vote. The Commissioner will grant the renewal if all is in order and issue a renewal approval letter or certificate for the next year. If the Commissioner has serious reservations (for example, declining outcomes or financial problems at the school), they can choose to grant only a conditional renewal (a shorter extension, such as 3 or 6 months) or refer the matter to the Council. A conditional approval during renewal means the school can keep operating for now, but must fix certain issues promptly to be allowed to continue for the full year. The renewal approval (full or conditional) will be communicated in writing. Should a school fail to submit a renewal or if its renewal is denied, the school’s approval expires and it must cease enrolling or teaching students in Rhode Island. Operating after a lapse is grounds for enforcement action. Therefore, timely and complete renewals are absolutely critical for the ongoing health of the school. Fortunately, the renewal requirements each year are fairly consistent, so schools that establish a good compliance routine typically secure renewals without difficulty.

Checklist of Required Items (Vocational School)

A proprietary school initial application must include a substantial set of documents and exhibits to demonstrate compliance. Below is a summary checklist of key items to be prepared:

• Application Form & Attestations: The official Initial License Application form, fully filled out and signed by the school owner or authorized representative. This includes basic info and some yes/no compliance statements. Additionally, a notarized Anti-Discrimination Compliance Agreement (a statement affirming the school will not discriminate on the basis of race, sex, etc., in its operations) must be signed and included.
  
  
• Ownership and Governance Documentation: A list of all owners, partners, or stockholders of the school (with addresses and contact info), and the names/titles of school officials and proposed administrators. Include copies of the organizational documents (e.g. Articles of Incorporation, partnership agreement, or DBA papers). If an owner is another company, include that entity’s governing documents as well. Also provide the school’s articles of association or bylaws if any, and any written conflict of interest policy governing the school’s leadership.
  
  
• Character and Qualifications References: At least three letters of reference attesting to the good character, reputation, and qualifications of the school’s owners or directors. These should ideally come from professional or academic associates who can speak to the integrity and competence of the individuals running the school.
  
  
• Personnel Qualifications: A detailed list of the school’s instructors and key staff along with each person’s resume or curriculum vitae. Include copies of any professional licenses or certifications held by instructors (for example, if teaching electrical trades, the instructor’s electrician license; for a medical billing course, perhaps a coding certification). Also attach job descriptions if available for instructors and administrators, to show roles and responsibilities.
  
  
• Proposed Catalog and Enrollment Agreement: A draft of the school catalog or student handbook that will be given to students. This should contain the school’s mission, admission requirements, program descriptions, course outlines, grading policy, graduation requirements, student conduct rules, refund policy, etc. Also include a blank sample of the student enrollment agreement/contract that students must sign, which sets the terms of enrollment. These documents are critical and must comply with all regulatory requirements (e.g. the refund policy in the contract must meet state minimum standards).
  
  
• Program Curriculum Outlines: For each education program or course the school intends to offer, provide a curriculum outline. This should list the courses or modules, with brief descriptions, the number of hours or weeks of instruction, and the skills or knowledge outcomes. Clearly indicate if a program leads to a specific credential (certificate or diploma) and include a sample certificate/diploma that the student will receive upon completion. If any program prepares students for a licensing exam (e.g. CNA, cosmetology), note how the program meets the required hours or content for that license.
  
  
• Academic Calendar: A projected calendar for the first year of operation, showing the start and end dates of terms or training sessions, scheduled breaks or holidays, and the expected enrollment dates (intakes). This gives regulators a sense of how the school will be scheduling classes and if downtime between sessions is reasonable.
  
  
• Tuition and Fee Schedule: A breakdown of all tuition rates and fees that the school will charge students. This includes tuition for each program, plus any additional fees (registration fee, lab fee, materials fee, etc.). The schedule should be clear and itemized. If the school plans to offer any payment plans or financing, that policy can be included too.
  
  
• Record-Keeping Forms: Copies of forms the school will use to maintain student records and administrative records. Examples: blank attendance sheet, academic progress report or transcript form, financial ledger card, diploma template, etc. Providing these shows that the school has a system in place to keep proper records for each student (a requirement for protecting students and aiding any transfers).
  
  
• Advertising and Marketing Materials: Samples of any advertisements, brochures, or promotional content the school has developed, including print ads, website screenshots, social media pages, etc. Rhode Island requires that advertising be truthful, so the OPC will review these samples. If some marketing is not yet created, a description of planned strategies can be provided, but the more concrete examples, the better. (Any slogan or claim, like “100% job placement!” must be supportable or it should not be used.)
  
  
• Facility Documentation: If the school has secured a location, include a copy of the lease agreement or deed for the school’s facility to prove you have the right to use the space. Additionally, crucial safety certificates must be provided: an inspection certificate or letter from the local fire marshal stating the facility meets fire safety codes, a letter from the local building inspector or occupancy permit showing the space is approved for educational use, and a letter from the Governor’s Commission on Disabilities (ADA) or equivalent proof of accessibility compliance. If the program involves any health/sanitation aspect (like cosmetology, barbering, massage), include a health inspection certificate from the Department of Health for those instructional areas. These approvals from local and state authorities are mandatory before the Council will license the school.
  
  
• Accreditation or External Approvals: If the school or any program has received accreditation or approval from another state, federal, or accrediting body, include documentation of that. For example, a school might be accredited by the Accrediting Commission of Career Schools and Colleges (ACCSC) – if so, show the accreditation certificate. Or if a program is approved by a national organization (like a truck driving program approved by the Professional Truck Driving Institute), provide that. While not required to have such approvals, disclosing them can support the application. If the school has no external approvals yet, a simple statement to that effect is fine.
  
  
• Teach-Out and Records Plan: A written plan for catastrophic events or closure, signed by the owners. This plan should explain how students will be notified and assisted if the school must close, how the school will arrange for students to finish their training elsewhere or receive refunds, and how student academic records will be preserved and made available (for example, by transferring them to the OPC or another custodian). All parties involved (such as a teach-out partner institution) should sign this plan. It’s effectively a contingency strategy to protect students.
  
  
• Surety Bond Calculation and Bond Form: Provide the calculation worksheet or formula used to determine the required bond amount (per the regulation’s standard formula based on unearned tuition). Initially, the school should submit its calculations of projected maximum unearned revenue, and OPC will confirm the bond minimum. Once OPC informs you of the approved bond amount, you must obtain a bond in that amount and submit the bond document (original or certified copy of the bond) naming the RI Council on Postsecondary Education as obligee. Ensure the bond is signed by the school (principal) and the surety company. Use the bond form format specified by OPC if provided.
  
  
• Other Information: Any additional materials that the Commissioner specifically requested during pre-application or that you feel support your application (e.g. community support letters, market studies showing the need for the school’s training programs, etc.). The Commissioner has broad authority to ask for more information to make a determination, so be prepared to supply anything that is reasonably related to the school’s operations and standards compliance.
  
  

As with degree institutions, the above checklist should be used in conjunction with the official guidelines from OPC to ensure nothing is overlooked. A neat, well-organized application that clearly labels each section (perhaps with tab dividers or an index) will facilitate a smoother review.

Fees & Timelines (Vocational Schools)
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State Exemptions

Rhode Island law and regulations exempt certain types of educational institutions or programs from the private postsecondary approval requirements. Below is a list of institution types and programs not required to obtain CPE licensing, provided they meet the specific criteria of the exemption. (Even if exempt, some may opt to seek approval voluntarily, but it is not mandated.)

1. Public and Governmental Institutions – Schools conducted under the public school system of Rhode Island are exempt. This includes public K-12 schools and the institutions in the state’s public higher education system (e.g. University of Rhode Island, Rhode Island College, Community College of Rhode Island). Additionally, any education or training program operated by a government agency (state or municipal) is exempt from Council on Postsecondary Education oversight.
   
   
2. Legacy Chartered Institutions – Any academy, college, or university that was established and continuously operating in Rhode Island for at least 10 years prior to April 13, 1932 is exempt by statute. Similarly, any institution established by a special Act of the Rhode Island General Assembly prior to January 1, 1987 is exempt. These provisions grandparent longstanding institutions (for example, older private colleges and universities with historic charters) from needing new approval under RIGL 16-40. Example: Roger Williams University in Bristol is explicitly named in the law as exempt – it falls under the category of institutions with a legislative charter and long history in the state. (Note: While these exempt institutions are not subject to CPE licensing, they typically are accredited and operate under their charters.)
   
   
3. Out-of-State Online Education under Reciprocity – An institution that offers postsecondary education exclusively via distance learning to Rhode Island residents can be exempt from state authorization if it operates under an interstate reciprocity agreement that Rhode Island participates in. In practice, this refers to the NC-SARA agreement (National Council for State Authorization Reciprocity). If the institution is based in another SARA member state, approved by that home state for SARA, and it has no physical presence in Rhode Island beyond distance education, then it may enroll Rhode Island students online without separate RI approval. The law (RIGL §16-40-10(b)) outlines conditions for this exemption: the institution’s home state must also be a SARA participant, the school must be in good standing in SARA, and it cannot establish a physical presence in RI beyond what SARA allows. This exemption streamlines purely online education across state lines.
   
   
4. Programs Approved by Other State Boards – Certain specialized schools or training programs are exempt because they fall under the jurisdiction of other Rhode Island regulatory boards. For example:
   
   
   
   • Driver Training Schools licensed by the Rhode Island Division of Motor Vehicles (Driving Instruction Schools) do not require CPE approval for their driver education courses.
     
     
   • Flight Schools that have a current Federal Aviation Administration air agency certificate (providing pilot training under FAA rules) are exempt from CPE oversight. The federal certification suffices for them to operate.
     
     
   • EMS/First Responder Training such as Emergency Medical Technician (EMT) courses that follow the U.S. Department of Transportation curriculum and are approved by the RI Department of Health are exempt. These programs are typically run by ambulance services or hospitals and are regulated by health authorities.
     
     
   • Hospital-Based Courses: Non-degree healthcare training programs offered by accredited hospitals (for example, internal hospital certificate programs for phlebotomy or medical assistants) are exempt, provided the hospital is accredited by the appropriate medical accrediting body. These are seen as extensions of patient care services and overseen by medical accrediting agencies instead of the Council.
     
     
   • Tattoo/Body Art Training: Training for occupations like tattooing, which are regulated through Department of Health licensing inspections rather than formal coursework requirements, can be exempt. The Dept. of Health’s Center for Professional Boards oversees these practices (ensuring practitioners demonstrate skills via inspection). If a “school” is purely teaching tattoo technique for a fee but DOH handles the licensing via testing/inspection, the program may not require CPE approval. (Any program claiming to certify tattoo artists would need to clarify this with DOH and OPC; typically, no lengthy course is required by law for such trades.)
     
     
5. Religious Institutions – Unlike some states, Rhode Island does not provide a broad statutory exemption for degree-granting religious colleges. All institutions awarding academic degrees are subject to the approval requirements unless they fall under another exemption (such as the historical exemptions in #2). However, purely religious training programs that do not offer recognized degrees and are avocational in nature (for example, a church-run ministry training that grants a certificate of completion) might be considered avocational (hobby/personal enrichment) and thus could be exempt under the avocational category (#6). It’s important to note that an institution calling itself a college or university and offering degrees (religious or secular) would generally need CPE approval in Rhode Island if established after 1932. Non-secular institutions seeking exemption often must limit their offerings to ecclesiastical education and may still apply for an exemption ruling from the Commissioner.
   
   
6. Avocational and Recreational Courses – Schools or programs that offer instruction exclusively for avocational, recreational, or personal development purposes (as opposed to employment purposes) are exempt. This would cover, for instance, a school of art that offers leisure painting classes, a dance studio teaching social dance courses, or a language school for travelers – as long as these courses are not advertised as career training and do not lead to a vocational credential. The key distinction is that the subject matter is for personal enrichment and not job-oriented.
   
   
7. Employer-Sponsored Training – Training programs offered by an employer for its own employees, at no charge to the employees, do not require state approval. Many companies have in-house training departments or corporate universities that teach job-specific skills to their staff. Since these programs are not open to the public and do not charge tuition (and typically do not grant any credential beyond perhaps an internal certificate), the state treats them as an internal HR function, not a postsecondary school. For example, if a manufacturing company runs a welding course to upskill its employees, that program is exempt from CPE licensure.
   
   
8. Test Preparation Courses – Programs or courses designed solely to prepare individuals for a professional licensure examination or other test, and that do not award any credit or credential, are exempt. For instance, a bar exam prep course for law graduates, an SAT prep course for high school students, or a short workshop to help nurses pass a certification exam would fall under this exemption. They are short-term and focused only on exam prep. (However, note that programs claiming to prepare for specialized certifications like IT certifications are not exempt if they are essentially vocational training in disguise – the regulations clarify that, for example, a course prepping for a Microsoft Certification exam still counts as a vocational program and needs approval unless it meets the short course criteria.)
   
   
9. Continuing Education for Licensed Professionals – Continuing education (CE) courses that are offered primarily to help licensed professionals meet ongoing education requirements and that do not award academic credit are exempt. For example, a seminar providing CPA continuing education credits, or a medical workshop for doctors’ license renewal, can be offered without CPE approval. These are usually short courses, often vetted by professional associations or licensing boards, and since they don’t confer new degrees or diplomas, the state doesn’t regulate them as schools.
   
   
10. Short-Term Courses – Education providers that offer only short courses of study (not part of a longer program) may be exempt if they meet specific limits: the course must be no more than 100 hours or 20 days in length and charge no more than $1,000 in total tuition/fees. Furthermore, the course has to be a standalone offering – not one module of a larger certificate program – and it must not be marketed as leading to any sort of professional credential (unless that credential can indeed be earned in 100 hours or less as defined by the certifying body). In other words, this exemption is meant for brief workshops or bootcamps. For example, a week-long photography bootcamp for $500 would qualify. But a series of ten 1-week courses that together confer a diploma would not be exempt under this rule. Providers of short courses must still apply to the OPC for an exemption determination; the exemption is not automatic. And they must renew the exemption yearly, confirming they still meet the criteria.
    
    
11. Product-Specific Training at Point of Sale – If a company provides free training in the use of a product that the customer has purchased, it is exempt. A common example: a software company selling an accounting software package might offer a free training session or online tutorial to the buyer or the buyer’s employees. As long as the seller is not primarily in the business of providing instruction and is not charging separately for the training, this instructional offering is exempt from regulation. The intent here is to allow businesses to train their customers on product usage without needing to become a licensed school.
    
    
12. Testing Services – Testing centers that solely administer standardized exams (like computer-based testing centers for professional exams, language tests, etc.) are exempt, provided they do not offer any instruction or test prep. For instance, a center where you can go take the GED or a Pearson VUE testing site for IT certifications does not need to be a licensed school as long as they are only providing the exam administration. These centers charge exam fees, schedule and proctor tests, and report results, but they don’t teach courses. They are explicitly carved out as not under CPE oversight.
    
    
13. Out-of-State Distance Instructors – An individual instructor located in Rhode Island who is hired by an out-of-state institution to facilitate an online course (distance learning) is not by themselves creating a “physical presence” that needs authorization, as long as that’s the extent of it. For example, if a professor living in Providence teaches online classes for a university in California, that alone doesn’t trigger a need for the California university to get licensed in RI. The Rhode Island-based instructor exemption means the presence of an instructor in RI (with no local campus or services) is allowed. The institution, however, must not conduct any other on-the-ground activities in RI beyond what’s allowed in the SARA/physical presence policy (like no recruiting office, no local student services). Essentially, this exemption complements the SARA distance learning exemption, clarifying that employing local adjunct faculty for online teaching is fine.
    
    
14. Recruiting and Information Dissemination – Out-of-state accredited institutions may come into Rhode Island to recruit students or advertise their programs without getting licensed, provided they do not collect fees or enroll students on the spot. For example, a regionally accredited college from Massachusetts can send representatives to a college fair in Rhode Island, hand out brochures, and discuss their programs with prospective students – none of that requires RI authorization, as long as they’re not actually signing those students up for classes or taking tuition payments within Rhode Island. They also cannot establish a continuous physical location – it should be occasional recruitment visits. The exemption in regulations specifically notes that accredited institutions can disseminate information in RI under these conditions.
    
    

Each of the above exemptions has specific definitions and limits, and schools/providers often must apply for an exemption determination from the OPC to ensure they are recognized as exempt. Exempt status is typically renewed annually (especially for those offering courses, to ensure they haven’t changed their scope). If there is any doubt, it’s advisable to contact the OPC with details of the program to get a written ruling on whether it is exempt or if approval is required. Remember that claiming an exemption without official acknowledgement can be risky – the Commissioner can rescind an exemption or determine that approval is needed if a provider strays beyond the exemption criteria. Always err on the side of transparency with the regulators when operating near the boundaries of these categories.

For personalized guidance on navigating the authorization process for your private post secondary institution in Rhode Island, reach out to Expert Education Consultants (EEC) at +19252089037 or email sandra@experteduconsult.com