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When college administrators and faculty members are unclear about how to comply with the Education Department’s rules, they would be wise to have defensible processes, Kerensky said

college’s policy for supporting regular and substantive interaction should be clear and should articulate a procedure for ensuring that the policy is enforced. Also, administrators and faculty should be able to argue why the policy and procedures are what they are. That way, should an audited institution be cited for a violation, their defense will be ready.