Key Considerations

Every state has authority to regulate institutions offering education to its residents, regardless of modality (face-to-face, online/distance) being used. As part of consumer protection for learners, states require institutions to obtain the necessary approvals and/or “state authorization” 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 clinicals, internships, field placements, and/or other learning experiences at physical locations within the state.

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). 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 instruction. Participating institutions agree to operate within policies and guidelines noted in the SARA Manual, including annual data reporting.

Participation in SARA provides reciprocity to offer distance education opportunities to residents of other SARA member states, without additional approval, in most cases, for activities such as:

• Limited field experiences* (such as clinicals, student teaching, internships, and other supervised learning experiences)
• Advertising to students (print, billboard, direct mail, internet, radio, t.v., etc.)
• Holding proctored exams
• One-on one in-person tutoring (no more than one student present in the same physical space at the same time)
• Short class meetings (no more than two meetings, totaling less than six hours, within semester-length course)

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 synchronous or asynchronous instruction
• Requiring students to physically meet in a location for instructional purposes (beyond the short course meeting provision)
• 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 provide a means for approval with professional licensing boards for programs leading to state licensure or national certification. Therefore, colleges/programs need to continue to monitor/comply with individual state professional licensure board requirements and/or seek approval from the board/s that oversee the profession in states in which they intend to enroll students. As a SARA member any courses or programs potentially leading to professional licensure must notify all applicants and students, in writing, as to whether such offerings actually meet state licensure requirements where the student resides. If the college/program cannot determine through its contact with relevant licensing entities whether the program meets licensure requirements in the student’s state of residence, the college may meet this SARA requirement by informing the student in writing and providing the contact information for the appropriate state licensing board/s in order for the student to make that determination.

For New DL Programs:

1. Know where your target students reside and if the state is a SARA member.
2. Review field experience requirements and other on-the-ground activities.
3. Understand which activities trigger physical presence or fall outside the scope of SARA and may require state authorization or approval by the agency/board responsible for professional requirements (in fields requiring licensure or certification to practice).
4. Contact Dawn Clineman, 513-556-5389, for consultation and additional information regarding State Authorization and SARA.
5. Submit the new program proposal to the Academic Committee.

Professional Licensure-Track Programs:

• Determine whether the academic program meets or does not meet educational requirements for licensure/certification standards in states in which you intend to enroll students.
• Develop program website disclosure/s regarding whether or not the program meets licensure requirements in other states.
• Develop communications/methods to notify individual applicants and students accordingly.