2017 PA-SARA Workshop: A networked state for student success by Sarah Zipf

There are two basic requirements for an institution to be considered legally authorized by a state for the purpose of Title IV program eligibility: (1) the state must authorize the institution by name to operate postsecondary educational programs; and (2) the state must have a process to review and act on complaints concerning the schools, including enforcing applicable state laws. (Institutional Eligibility, 2017, pp. 2-5).

On November 29, 2017, the second annual State Authorization Reciprocity Agreement (SARA) workshop for Pennsylvania was held at University Park, PA and more than 50 postsecondary institutions were represented. The workshop was geared towards educators and staff working to meet compliance standards and reporting requirements of SARA and other related distance education regulations. All SARA-membership institutions in Pennsylvania were invited to this one-day workshop to discuss and train on SARA specifics with leaders from the Commonwealth, the regional compact, and national leadership from the National Council on SARA (NC-SARA). Pennsylvania became an affiliate of the Southern Regional Education Board (SREB) and a SARA state in 2016.

The one-day workshop combined presentations, panel discussions, and question and answer periods. Representatives of SARA member schools posed numerous questions to the leading experts of state authorization regarding the upcoming implementation date of July 1, 2018 for when compliance of state authorization rules, as related to distance education, goes into effect. For example, the regulations do not currently provide details of reporting requirements or example language for necessary disclosure notices. While this is not a conference for graduate students, per se, the information presented showed the internal workings of the administrative side of how educational delivery happens.

Marshall Hill, one of the founding architects of SARA, provided a historical account of state authorization. State authorization is not a new rule, but rather was overlooked by the majority of colleges and universities until it was added to the financial aid auditing process—at which point institutions realized the need to comply. Simply put, Dr. Hill explained in his presentation that the true benefit of SARA makes state authorization “effective and uniform” from one state to the next and provides reciprocity. State reciprocity is the federally accepted practice of exchanging and cooperating with regulations and rules of others states for a collective benefit (see Contreras, 2017). Often driver’s licenses are used as an example of state reciprocity; a PA driver’s license is recognized as a valid license by all other states, even if there are slight differences in other states. Schools must be authorized by their home state to provide educational activities either through state statute, charter, constitutional provision, or an otherwise defined action by that state entity. Likewise, educational activities taking place outside of the school’s home state must be authorized in the other state.

[T]he true benefit of SARA makes state authorization “effective and uniform” from one state to the next and provides reciprocity.

At the heart of the state authorization regulations, is the protection for students studying through distance education. Distance education is any educational activity that takes place when the student and instructor are separated by physical location, like an offsite internship or online education (Manual, 2016). State authorization seeks to ensure the state in which the student is located is authorized to provide the educational activity (Cummings, 2011). The regulations of state authorization are complex and require attention to specific academic programs, licensure requirements, and disclosure notices for the protection of students. State authorization requires the institution to seek permission from each state, individually and in a non-standardized way. Historically, the school-to-state authorization was cumbersome and costly with individual state payments and additional administrative work. A state’s participation in SARA means a single application for authorization in nearly all states for institutions that chose to become members. SARA is not a federal regulation, but rather an agreement between states to acknowledge and abide by similar rules for the protection of students and mitigates financial liability. Through SARA, institutions are able to meet the federal regulations that require authorization by states.

Currently, there are 92 institutions in Pennsylvania that belong to SARA. Some critics believe the cost of becoming a SARA member institution is too expensive and would add a new line item in their budget. However, many schools overlooked state authorization regulations for decades. If schools had been compliant with these regulations from the start, there would have been a deep cost differential for becoming SARA member institutions. While there is a focus on the cost increase to join SARA, it is important to note that multiple schools saw a decrease in costs after joining versus paying each state individually. Penn State, for example, paid $60,000 to the Commonwealth for application and $6,000 to NC-SARA for membership. In previous years, states’ authorization costs varied by the number of students or programs in that state, required bonds, or changed costs from year to year which made budgeting more difficult and cost much more for institution-to-state authorization.

Joining SARA is voluntary. As discussed above, SARA can certainly streamline the efforts of educators and save institutions money. Ultimately, SARA functions to protect students from degrees that cannot be used to sit for professional licensure and other malicious misrepresentation from a school. State authorization is not the sexiest topic in higher education, but it certainly is important. Working together across our state during the workshop, it was apparent that Pennsylvania educators and staff are interested in following policy, seeking out best practices, and doing right by students. Other states are investigating similar workshops as a means to understanding compliance standards and the benefits of joining SARA. As the compliance deadline nears, it may prove beneficial to other states to visit with leaders, state regulators, the Department of Education, and other postsecondary institutions to fully understand these requirements.

For more information about State Authorization, the NC-SARA.org website is available as a resource and includes detailed information about state costs, SARA member schools by state, and current topics. Additionally, the book State Authorization: A Handbook for Institutions and Agencies (2017),  edited Alan Contreras, provides a history, legal decisions for degree-granting authority as it relates to state authorization, and information related to professional licensure requirements.

References

Contreras, A. (Ed). (2017). State Authorization: A Handbook for Institutions and Agencies. CreatesSpace Independent Publishing Platform.

Cummings, J. (2011). Online Learning Challenges: State Authorization, Federal Regulation. Educause Review, 110-111.

Institutional Eligibility. (2017). Federal Student Aid Handbook, Volume 2, Chapter 1. Retrieved from https://ifap.ed.gov/fsahandbook/attachments/1718FSAHbkVol2Ch1.pdf

Manual (2016). National Council on State Authorization and Reciprocity Agreement. Retrieved from www.nc-sara.org 

Sarah Zipf is a PhD student in Higher Education at the Pennsylvania State University. Sarah’s professional experience as a financial aid administrator shaped her research interests in adult students, financial aid, and distance education. She currently works as a graduate assistant for the division of Outreach & Online Education in compliance and reporting, working with state authorization regulation.