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It would be interesting to take a close look at how you identify your on-campus students. In my experience, many (most?) campuses do not do a formal “identity proofing” of their on-campus students. Not that it makes the on-line case any easier…



InCommon has been working on this problem through what we call the assurance program,

What the assurance program gives you is an auditable standard for identity proofing and authentication. This program is approved as meeting the federal government's Identity and Credential Access Management (FICAM) standards.  What this does is lays out what documents and standards are needed for identity proofing. Using this you know you are safe by following best practices.

Related to the assurance program is the Multi-factor authentication initiative. This allows you to require a second factor for services. 

Tying these both together is a pilot project I mentioned a few weeks ago named CommIT. The  CommIT project will give you an identity proofed credential for a student. You would then not have to do the identity proofing. More on CommIT is at

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