8VAC40-31-160 E - 3.  With regards to records alteration, what records are being referred to in this statement?  Final transcript or formative documents like course grades in the LMS?

N-5  This section is confusing.  12 days, 14 days??

N-6  Leave of Absence - We provide for an LOA of up to one year.  If a student is out for 6 months or more then for financial aid purposes, they would have to refile new paperwork (FAFSA etc).  But most of our courses are offered only once/year, so for academic purposes, we give them up to a year.  This proposed change would impact our policy and our retention rates since a student that is on LOA is still counted as a retained student according to ACICS.  If we are required to limit this to 6 months, then the student would be withdrawn from the college at 6 months and have to reapply to return when their course is offered again (assuming they need to stay out for greater than 6 months)

Renewal Fee - the proposed fee for our institution will double from 2500 to 5000.  For a non-profit, healthcare system based college, this is a significant hit to our budget.  $2500 is a very significant number to us in regards to supplies for skills labs, equipment for teaching etc.  It might be easier to adjust to a phased in increase over 2-3 years.