Compliance

I. Introduction: Change over fifty years


DIRI as an organization has dramatically changed and evolved over the last fifty years. Where The Rolf Institute® of Structural Integration, now doing business as the Dr. Ida Rolf Institute ® (DIRI), was once an informal organization-- part of the human potential movement started at the Esalen Center and focused on the powerful person of Dr. Ida Rolf-- the Institute is now much more defined as a non-profit, state and federally recognized, private occupational school.  Everything about the DIRI organization, except arguably the mission, is structurally different from those early days, including the legal, regulatory, governance, financial, operational and employment structures.

 
Change is never easy, and often, there is a sense of losing the magic, nostalgia, and even discontent.   As time goes by there is often an increasing incongruency between expectations of those in the organization and the nature of the organization’s evolving legal and business identity. The culture and structures of the organization lag, even as the organization redefines itself.  DIRI is and has been in such a change process. 
The changes to DIRI over the last twenty years have come with increasing regulatory constraints that can prove frustrating and limiting. But, as is often the case, with increased accountability also comes increased professional credibility.  The Dr. Ida Rolf Institute® is accountable and recognized by Federal, State, and National agencies/organizations, which in turn, opens the door to increased funding such as Title IV Student Loans and U.S. Department of Education and other .gov grants. It also opens the doors for our practitioner/members for recognition from state licensing boards, continuing education agencies, and the public at large.  

II. Regulatory Oversight: Understanding the DIRI accountability structures.


Internal Revenue Services (IRS)
The Dr. Ida Rolf Institute is defined as a 501 c (3) non-profit, educational organization. As an educational organization, it is different from a 501c (6) membership organization, or some other type of nonprofit organization.  

Nonprofit 501c(3) Status   https://www.irs.gov/charities-and-nonprofits

Independent Contractors vs employees  https://www.irs.gov/taxtopics/tc762


Colorado, Department of Private Occupational Schools (DPOS)
The Dr. Ida Rolf Institute is licensed as an occupational school by the Division of Private Occupational Schools (DPOS). DPOS is a state agency within the Colorado Department of Higher Education that is statutorily charged under the Private Occupational Education Act of 1981, with overseeing postsecondary private occupational schools and its delivery of occupational education.  According to the DPOS mission statement they provide standards for and foster and improve private occupational schools and their educational services, and protect the citizens of this state against fraudulent or substandard private occupational schools.  Because DPOS is concerned with protecting the citizenry and preventing possible fraud, they have intense focus on processes where students might be fraudulently enrolled, charged, and/or dismissed from a program.  While they review all facets of the school operations, they focus particularly on admissions processes, Title IX discrimination laws, faculty quality, financial viability of the institution (including surety bonds, etc.)  student complaints, and other related processes that may indicate fraud. For example, every year we report on the quality of our faculty (transcripts, trainings, etc.), admissions numbers, transfer of credit hours, and any logged complaints by students. (See Appendices for DPOS standards.)  

To learn more about DPOS go to  https://cdhe.colorado.gov/about-dhe/divisions/division-of-private-occupational-schools


Commission on Massage Therapy Accreditation (COMTA)
In addition to being licensed as an occupational school by the state of Colorado, DIRI is also accredited as a school by the Commission on Massage Therapy Accreditation (COMTA).  COMTA accredits schools based on a set of administrative and educational standards (see Appendices).  They conduct site visits and require annual reporting on specific data relevant to administrative and educational quality of the programs offered through the school.  These regulations go beyond organization operations to focus in detail on areas such as classroom instruction, syllabi, curricula development, faculty training and qualifications, recruitment, assessment and placement of students, and general administration.  

  • Curricula, Instruction and Assessment-Must have documents and processed
  • Classroom Instruction-requirements for syllabi, materials, distance learning, etc. 
  • Continuous School Improvement Processes-Student progress data, graduation rates, placement
  • Title IV compliance
  • Financial Viability of organization-Annual financial reporting 

To learn more about COMTA accrediation go to  https://comta.org/comta-endorsed-curriculum/


US Department of Education (USDOE)
Once accredited, DIRI is eligible to apply for Title IV USDOE loans for students.  There is an entire Financial Policy and Procedures Manual (FPP) , which outlines the limitations DIRI must meet in administering these funds.  While much of these regulations fall on administration, some directly impact how faculty must conduct instruction of students, for example the Satisfactory Academic Progress policy. There are also many regulations around clock hours, student information, attendance, Individuals with Disabilities (including learning disabilities, discrimination, etc. 


Trademarks for Rolfing®  as an asset and fiduciary responsibility


The Dr. Ida Rolf Institute® primary offering is certification and training in Rolfing® Structural Integration and Rolf Movement® Integration.  In return, the Institute charges tuition and licensing fees of members.  In a nutshell the business of the Institute is the trademarked educational offerings and supporting our members in opening quality businesses under the trademark.

 
The Rolfing® trademarks are valuable and as an organizational asset need to be protected. The DIRI Board of Directors has the fiduciary responsibility to ensure that this asset is not devalued by allowing it to be used freely, without licensing, or a return on investment.  Giving away the DIRI curricula, the right to grant certification of students and teachers, professional programming, etc. especially without charging for the intellectual property covered by the marks demonstrates a lack of fiduciary oversight.  Therefore, it is important that DIRI not allow others to use the trademarks, or products developed under the marks. For membership this is clear cut. But it also applies to the faculty use of trademarked products. For example, it would devalue the marks to allow faculty to teach DIRI curricula materials to another school or educational institution, without charging for the marks or the use of the materials. Similarly, it would devalue the marks to grant Rolfing credits or Rolfing certifications without the Institute receiving a return on this investment. 

III. Conclusion

As an approved and licensed school, it is important that our business model, our policies, our member agreements and our contracts with faculty are aligned with our mission and do not set us up for failure as an Institute of Higher Education and an alumni/membership organization. We need a clear and common vision focused on making the Dr. Ida Rolf Institute the best school globally for Structural Integration, the continued education and support of members, and the promotion of Rolfing® work as a separate and distinct field from other modalities.