SARA does not deal with professional licensing board approval for programs leading to state licensing in fields such as nursing, teacher education, psychology, etc. We acknowledge the seriousness, pervasiveness and complexity of that issue; but, for now, SARA provides no solution. That is an additional challenge that will require future attention. Waiting to roll out SARA until we had that issue resolved could, in our view, delay SARA implementation by several years.
SARA also does not deal with offerings provided free and beyond the scope of current regulation of the degree programs of accredited academic institutions (free, non-credit MOOCs, etc.). Nor does it explicitly deal with non-credit instruction, although if an institution participates in SARA, its for-credit and non-credit activities in SARA states are covered by the agreement.