Board members of the National Council for State Authorization Reciprocity Agreements (NC-SARA) assembled on December 2, 2014 in Atlanta to decide on a number of items essential to the initiative’s continued development.
These 21 leaders from various sectors of higher education and government help guide the activities of SARA, a nationwide initiative of states that will make distance education courses more accessible to students across state lines and make it easier for states to regulate and institutions to participate in interstate distance education. The effort is funded by a $3 million grant from Lumina Foundation, $200,000 from the Bill & Melinda Gates Foundation, and fees paid by institutions.
“The SARA initiative has made significant progress since opening doors for states to join in January 2014,” noted Marshall A. Hill, executive director of NC-SARA. Hill reported that 17 states (Alaska, Arizona, Colorado, Idaho, Indiana, Kansas, Louisiana, Missouri, Montana, Nebraska, Nevada, North Dakota, Oregon, South Dakota, Virginia, Washington and West Virginia) have joined SARA. He also stated that as of December 2, 2014, SARA-enabling legislation has passed in an additional eight states and three more have determined that no legislation is needed to enable participation.
The board gave final approval to two policy issues that were first considered at the meeting on May 14, 2014: 1) policy on data to be submitted by SARA institutions, and 2) policy on reporting of complaints. Based on recommendations by SARA staff and an advisory committee, the board approved data requirements to be reported annually to NC-SARA starting in fall 2015. The data will be reported on the NC-SARA website; its collection is designed to improve national information on SARA institutions serving students who live in other states. Similarly with staff and committee advice, the board approved the quarterly reporting by SARA states of appealed complaints. Required reporting will begin in April 2015, and the gathered information will appear on the NC-SARA website to provide timely identification for students and states of any SARA institution for which complaints are appealed to their state’s SARA portal agency. The context of that reporting will include the institution’s total out-of-state distance education enrollments.
The board also approved clarification of the term “legal domicile” and the addition of the possibility of institutions being approved by their states to join the initiative on provisional status. The definition added to the NC-SARA Policies and Standards identifies the “legal domicile” of an institution for purposes of SARA eligibility as the state in which the institution’s principal campus holds its institutional accreditation and, if applicable, its federal OPEID number. By creating the possibility of provisional status for some institutions, the board addressed the concerns of some SARA states about institutions that meet current SARA eligibility requirements but have other problems/challenges of which the state is aware. This permits special attention for institutions facing academic, financial and consumer issues.
In terms of physical presence standards, the board approved modifications to the NC-SARA Policy and Standards regarding clinical placements and recruiting. Clinical placements would be removed from the “Physical Presence” subsection, recognizing they are a unique and significant aspect of SARA that will require continuing work. A detailed explanation of supervised field experiences covered by SARA, including contracts and licensing, was provisionally approved by the board, subject to review of a re-draft. And the board agreed to add recruiting to the list of activities by SARA institutions that do not trigger physical presence in SARA states. That provision is already included in the regional SARA agreements.
A progress report was given on a number of items including NC-SARA’s pursuit of 501(c)3 status. Members of the NC-SARA executive committee voted to initiate the process of obtaining 501(c)(3) federal tax-exempt status for NC-SARA based on analysis provided by EducationCounsel, LLC. The process, including preparation of the application, is estimated to take six to nine months. New FAQs on SARA’s use of federal composite scores; states’ use of those federal scores in determining institution eligibility for SARA; tutoring and physical presence; and aviation programs were also brought to the board’s attention.
The NC-SARA board is a nationwide coordinating entity that assures the four regional compacts establish uniform standards and procedures for accepting and monitoring states participating in each of their respective regional reciprocity agreements. The NC-SARA board includes the chief executive officers of the four regional compacts, four leaders from the National Commission and Presidents’ Forum/Council of State Governments efforts, and additional members to assure that the perspectives of all stakeholder groups will be represented. A list of members is available at: www.nc-sara.org/about/national-council