SREB State Authorization Advisory Committee Meeting April 30-May 1, 2013 Atlanta

Welcome and Introductions Meeting Agenda and Objectives Review of the latest documents * APLU Commission Report * SARA Implementation Processes * W-SARA * SECRRA 2

Changing State Roles (for SARA States) Home State/Host State Model “Drivers License” approach--‘Approval’ from home state recognized in other states State procedures will need to be established Designation of an agency, or agencies, to conduct reviews States with no current authorization processes in place would need to establish same

Regional Higher Education Model Adopts all elements of Commission report (SARA/W-SARA merged…) Each regional compact would work with its member states to promote/execute SARA Four would reach ‘common’ approach to facilitate a nationwide agreement Simpler administrative structure Arrangements for participation for three states that do not belong to one of the compacts National structure…

SARA Implications for SREB States Given the regional model to the national plan SECRRA designed to be a ‘bridge’ to any national reciprocal agreement BUT SOME SIGNIFICANT DIFFERENCES All USDE recognized accrediting bodies Inclusion of for-profits Who ‘signs off’ in home institutions Fees Data collection/reporting Complaint procedures

“W-SARA” Initiative originally of the Western Interstate Commission of Higher Education and the other three ‘sister’ regional compacts that would… develop a nationwide reciprocal process through the regionals utilize SARA principles in a more simplified way provide a more streamlined administrative structure More academic and ‘friendly’ presentation

Creating ‘S-SARA’ Should reflect the previous efforts by SREB and its states Must embrace broader national principles of SARA Should follow the basic structure/outline of W- SARA to ensure it ‘harmonizes’ with the other regionals The proposal to Lumina and implications for our work (Mary Larson)

A Review of the Indianapolis Meeting Mary Larson Others there…

The DeFilippo Manifesto… Accepting US Dept. of Education Accreditation in full satisfaction of quality assurance Physical presence and the allowance for blended programs Role of the Regional Compacts/SARAs Annual recertification (?) Avoiding overweening agreements Logistical feasibility prognosis SARA on a path to its own demise…

Questions, Questions?! Could a governing board, such as a board of regents, serve as the approving agency and the agency to address complaints, assuming a different agency other the state SHEEO, serves as the lead agency? If a non-home state wanted to investigate and attempt to resolve a complaint, what laws (specific to postsecondary education) would apply – the home state or non-home state?

Questions, Questions?! One comment made during the SREB breakout session was that the regional compact would set minimum advertising and recruiting standards. During an open session David Longanecker stated that states may enact regulations that are more stringent than the standards adopted as part of SARA. Given this, could a home state institution be subject to different advertising/recruiting restrictions than an out-of- state institution approved by its home state? How will SREB monitor states’ compliance with the reciprocity agreement?

Questions, Questions?! There seems to be a lot of reliance on IPEDS data. How will SREB account for IPEDS graduation data being limited to first time/full time students? The states seem to be tasked with ensuring that federal disclosure requirements are met. What role will USDOE play or will the regional compacts adopt the federal disclosure requirements as their own? How would institutional closures be addressed? Would the home state be responsible for administering the closure for all students? How would the fact that states have different closure funding mechanisms (e.g. tuition guarantee funds or bonds) be addressed? What about student records?

Questions, Questions?! It is our understanding that an institution will not create a physical presence if it has experiential learning opportunities in a state as long as the institution has obtained necessary licensure approvals and only 10 students are present at one time at a single field site. Assuming this understanding is correct, which state, the home state or non-home state, will be responsible to verify that the institution is not creating a physical presence in the various states? Will SREB set a minimum bond amount for consumer protection issues?

Questions, Questions?! How will SREB clarify which programs or institutions will be subject to reciprocation. It seems clear for institutions that are 100% online, but what about institutions that offers program through a blended delivery mode? How will SREB define home state, e.g., state of incorporation, OPEID, brick & mortar central office?

Questions, Questions?! How will SREB address a situation where some programs may be appropriate for reciprocity but others are not appropriate? For example, an online institution is approved for reciprocity but its teacher licensure program is not approved for licensure in Tennessee. Will the entire institution be prevented from participating in SARA or just from enrolling students in the teacher licensure program? Will (should) SREB include language that will explicitly recognize that states should adopt a fee structure that ensures that non-reciprocity institutions will not subsidize the reciprocity activities?

SREB SECRRA All states were asked to re-affirm original reciprocity arrangement in writing States could opt in/out in RECIPROCAL…states not agreeing to participate will be required to seek approval in other SREB states Impacts EC and ACM/EC programs All but two states have ‘re-upped’ (AL, FL)

Moving from SECRRA to SARA -SREB is fully supportive of the national SARA model and effort and is committed to working to fully implement it -Cannot have a ‘competing’ process (some would say a ‘backdoor’) to reciprocity -How to move (what should be the trigger?) -When to move- -How to frame the move -Next steps