Regulatory Alignment and Compliance

Key Education Regulations

RP is a for-profit educational organization, so it is not mandated to comply with laws or regulations for federally or state funded institutions. However, as a tutoring company, we are still obligated to comply with the regulations of the institutions that our students attend. The primary regulations that apply to this Change Implementation Plan include the Individuals with Disabilities Act (IDEA) and Section 504 of the Rehabilitation Act of 1973 (Section 504), Every Student Succeeds Act (ESSA), Federal Educational Rights and Privacy Act (FERPA), and the Children’s Internet Protection Act (CIPA). Additionally, the standards outlined by the International Society for Technology in Education (ISTE) apply to online educators.

The support of online tutoring in its nature is provided to students in need; the nature of that need is as variable as the students themselves. Many students enroll in tutoring to find the support or specialized intervention that they do not receive in their traditional classrooms. IDEA requires educational institutions to provide and support Individualized Education Plans for students with diagnosed learning disabilities, while Section 504 requires provision of equal learning opportunities for students with broader disabilities (Individuals with Disabilities Education Act, 2024 and Section 504, Rehabilitation Act of 1973, n.d.). Regardless of the tutoring product (holistic vs. “on demand”), tutors are required to assist students in every way they are able to in order to meet their learning needs. The online nature of tutoring means that multiple technological accommodations can be implemented, such as text-to-speech or speech-to-text, specific fonts for different visual or processing challenges, changes to velocity of material delivery to accommodate learning needs, or simply the added positive support of a tutor. When evaluating the shifts to the different product offerings, however, a more “in-demand” program would necessitate the tutor focusing less on long-term learning skills such as executive functioning, alternative approaches to material learning, or skill development due to the limited nature of potential single one-hour or half-hour classes.

Every Student Succeeds Act is another regulation that was enacted to provide accountability for learning institutions and ties federal funding to evidence of learning, which is most often exemplified by regular standardized testing (Every Student Succeeds Act (ESSA), n.d.). Many states and districts have chosen the college entrance assessments of SAT and ACT as their accountability assessment, meaning that students that come to tutoring for test prep support may be looking for additional support for either required testing or for the more high-stakes prospect of college applications. The two products, then, are equally suited to address the needs of the two different motivations: “on-demand” or academic tutoring is well suited to support the knowledge and content acquisition for the required-testing motivated students, while holistic tutoring integrates meta-cognition, test taking strategies, and long-term learning skills for high scores needed for college admissions.

An added concern for online tutoring is students’ digital safety and right to privacy, which are addressed by FERPA and CIPA. The majority of students that enroll in online tutoring are middle through high schoolers, and their grades are requested by the tutor to capture the breadth of students’ abilities, academic growth, and impact of the program. Parents often share this information with the tutor. However, college students and adults often come to RP for support as well, and tutors must be cognizant of when and how they are permitted to share the specific numerical performance of adult students with their parents or other family members, as FERPA provides adult students with autonomy and privacy over their grades (United States Department of Education, 2017). These adult students sign up for both academic-specific support and holistic support, and each program needs to be addressed individually. Online learning, the use of digital tools and the internet, and the use of connected devices also open students to a wealth of data privacy and security concerns which is often mitigated by family or school implemented controls on devices or internet access. CIPA was enacted specifically “to address concerns about children's access to obscene or harmful content over the Internet”, and applies to both holistic and “on-demand” tutoring programs (Children’s Internet Protection Act (CIPA), 2024). While all tutors hired at RP are adults with college degrees and education experience, it serves all stakeholders to remind them of their ethical obligations to avoid adult content and instill digital literacy into their lessons.

Finally, as online educators, tutors at RP are held to ISTE standards, which are both broad in scope and specific in purpose. The Education Leaders standards encompass requirements to serve as Equity and Citizen Advocates, Visionary Planners, Empowering Leaders, Systems Designers, and Connected Learners (ISTE, 2025). In short, these guidelines provide a framework for tutors to serve as responsible educators through specific lenses of inclusion and coaching students towards global citizenship.

Regulatory Impact

The separation of online tutoring into two distinct programs - holistic and “on-demand” (or academic) - requires mainly the consideration of short term vs. long term goals. While elements of all referenced regulations are applicable to both, some regulations require more consideration during holistic programming than academic tutoring.

IDEA & Section 504 - Accommodations for disabilities of all students need to be considered in any educational environment, but the online educational environment can also be limiting. Assistive technologies can be used when needed, applicable pedagogical techniques and curriculum adaptations executed as necessary, and behavioral and personal traits taken into consideration for every individual program. However, longer-term or holistic programming has the potential to integrate deeper learning techniques, coping strategies, and thoroughly personal support for students wanting to develop the skills to learn independently or alongside accommodations. Academic tutoring, with the program’s short-term goals, highlight immediate completion of assignments, exam review, and content support, and lack the time frame required for wide applications of an IEP or a 504 plan. The change to tutoring overall will be to highlight how to apply accommodations differently depending on the program goals.
ESSA - ESSA most directly applies to students’ completion of standardized tests, whether they are the SAT, ACT, STAR Test, NY Regents Test, or another state-required standardized assessment. One major consideration regarding the shift in programming implemented in this Change Plan is the purpose of the test itself, i.e. whether it’s being used for school acceptance or placement, or whether the student is taking it for completion scores only. Academic tutoring programs will be best to support the completion-only motivated students that need direct remediation or content-related support, while holistic tutoring will address the higher-order skills needed to acquire higher scores for placement or school acceptance. Changes to the programming include separation of specific skills focused on in the programs themselves that highlight the students’ goals.
FERPA & CIPA - These acts are rarely touched on at RP and will need to be highlighted more in depth. The differences in programming are not impacted by these regulations, but specific skills related to digital literacy (CIPA) can be emphasized more distinctly with holistic programming over academic tutoring. Adult student grades (FERPA) are rarely taken into consideration except for certain types of parent communication, and depend on the purchaser of the program, the relationship to the family and student, and the students’ permissions and goals.
ISTE Standards - ISTE standards for Education Leaders should be in place regardless of programming and as minimal standards of tutor performance. Holistic programming can accommodate longer-term emphasis on digital citizenship, deep learning, and various developmental progress, while academic programming should not avoid topics of ethics, process, or professionalism.

Stakeholder Communication Plan

There are two main aspects of the shift in programming offerings that will need to be communicated regarding regulations. Yet again, this relates to the overall goals and time frame of the programs. Communication around the articulated differences will be executed in multiple forms: targeted professional development for both faculty and sales departments, policy updates on the shared database, individual conversations in one-on-one meetings, and emailed reminders to the faculty. Policy updates will include FERPA Compliance and an Internet Safety Policy, while differentiation of program focus and strategies for progress will require more in-depth training and individual coaching.

The training and professional development executed will be separated into one desgned for the faculty/tutors and one to the sales/advisor teams. Highlighting specific program goals and needs will help identify which program is best for the family, and will allow both teams to identify and communicate strategies and growth in a more personalized, targeted manner. Holistic programming will encompass skills required for long-term growth and development, and it will be able to take into account development alongside any present disabilities or learning challenges. Academic programming will incorporate accommodations from IEPs and 504 Plans, but will be limited in its ability to address adaptations or skill development over time. ISTE standards will be reiterated in training as well as linked to the database, and an emphasis on appropriate internet and AI use will be incorporated as well.