Key Considerations

Students walk in front of UC's McMicken Hall on a bright day

Every state has statutory regulations for out-of-state institutions offering online education to its residents. Many states require programs to be authorized before offering courses and/or operating in their state. "Operating" may include solicitation, advertising and/or recruiting students, as well as requiring students to complete clinical, internships and/or field placement courses.

State Authorization Reciprocity Agreement

The University of Cincinnati has been approved by the Ohio Department of Higher Education to participate in the National Council for State Authorization Reciprocity Agreements (NC-SARA) initiative. This voluntary agreement among member states and institutions establishes standards for interstate offering of distance education across state lines, shifting principle oversight responsibilities from the state in which the distance learning is being received to the “home state” of the institution offering the instructions. The NC-SARA Manual details policies and guidelines for operating under SARA.

Participation in SARA provides reciprocity to offer online/distance learning programs to residents of other SARA member states (click here for the list of current SARA states), including the following activities:

  • Limited interstate field experiences (such as clinical, student teach, internships)
  • Interstate advertising to students (print, billboard, direct mail, internet, radio, t.v., etc.)

SARA does not cover physical locations.  The following activities are outside the scope of SARA and may require state authorization:

  • Establishing a physical location for students to receive instruction
  • Requiring students to physically meet in a location for instructional purposes
  • Establishing an administrative office or physical site operated by or on behalf of the institution in the state;
  • Providing office space to instructional or non-instructional staff
  • Maintaining a mailing address or phone exchange in the state

SARA has no effect on state professional licensing requirements. SARA does not deal with professional licensing board approval for programs leading to state licensing. Therefore, colleges/programs need to continue to monitor/comply with individual state licensure board requirements.  Any courses or programs potentially leading to professional licensure must keep all students informed as to whether such offerings actually meet state licensure requirements, or tell the students that the college does not know whether the program meets requirements in the state and the student must make that determination.

Not every state is a member of SARA. 

For New DL Programs:

  1. Know where your target students reside and, if State Authorization is required in that state.
  2. Understand which activities trigger physical presence.
  3. Review your program marketing campaign and field experience requirements.
  4. Submit the new program to the Academic Committee.
  5. Contact Melody Clark, to seek State Authorization.  

Common Physical Presence Triggers:

  • Mailing Address, Telephone Number or Facility within another state
  • Field Experience (Clinical, Practicum, Internship)
  • Local Advertising (Billboards, Newspapers, Local TV/Radio)
  • Advertising or Soliciting a specific Geographic Target
  • Employing Faculty in another State
  • Articulation Agreements with other Institutions