1. An Overview of State Authorization and SARA An MCCA Webinar Wednesday, November 4, 2015

2. Ronda Edwards Executive Director Michigan Colleges Online Michigan Community College Association 222 N. Chestnut Street Lansing, MI 48933 -1000 517.372.4350 https://www.micollegesonline.org/ www.youvegotthis.org Organized today by

3. wcet.wiche.edu Presenter Cheryl Dowd Director, State Authorization Network WCET - WICHE Cooperative for Educational Technologies 3035 Center Green Drive Boulder, CO 80301 303-541-0210 cdowd@wiche.edu 3

4. 4 Presenter Jenny Parks Director, Midwestern Regional State Authorization Reciprocity Agreement (M-SARA) Midwestern Higher Education Compact 608.461.0138 jennyp@mhec.org www.mhec.org jennyp@mhec.org www.mhec.org

5. Who are all these SARAs??? State Authorization Reciprocity Agreement

6. Who are all these SARAs??? M-SARA: Midwestern (MHEC) N-SARA: Northeastern (NEBHE) S-SARA: Southern (SREB) W-SARA: Western (WICHE)

7. NC-SARA A nation-wide system of reciprocity administered by the four existing regional higher education compacts WICHEMHEC NEBHE SREB

8. Who are all these SARAs??? NC-SARA National Council for State Authorization Reciprocity Agreements

9. 34 states have already joined! Just accepted yesterday… Alabama Georgia Maryland Mississippi Texas Maybe in 2015… Rhode Island

10. What’s in the future for SARA? 2015 34+ states 500+ institutions Single unified agreement 2016 45 states expected 1000-ish institutions expected

11. SARA: a part of your state authorization strategy ? Seek “authorization” in as many as 54 states and territories Seek “authorization” in 54 minus the number of SARA states One approval for all SARA states

12. SARA Resources and Documents 12 NC-SARA Policies and Standards: http://nc- sara.org/files/docs/FINAL%20SARA%20General%20Policies%20released.p df Michigan Institutional SARA Application: https://www.michigan.gov/documents/lara/PPS030_7-15_495241_7.pdf NC-SARA Website: http://nc-sara.org/http://nc-sara.org/

13. wcet.wiche.edu State Authorization Compliance Strategy 1 st Step: Institutional and State Regulation Analysis 1. Institutional analysis of out of state activities – Where does the activity take place? Including but not limited to: a. Where are the students? (online and field experiences) b. Where is the faculty? (those that teach remotely) c. Where is the institution recruiting? d. Where is the institution marketing? 2. Knowing the requirements in each state a. Regulated activities vary by state b. Process for compliance varies by state c. Fees for compliance vary by state Photo credit: Open Clip ArtOpen Clip Art

14. wcet.wiche.edu The Analysis Resources Secondary and Primary Sources to Guide the Institution to Compliance WCET - State Authorization Network Support Organization – research, experts, networking SHEEO State Authorization Surveys Surveys of information for each state State Agency Websites Most links found in the SHEEO Surveys State Laws and Regulations Most links found in the SHEEO Surveys Other Important Federal Regulations 34 CFR 602.17 34 CFR 602.17 – Application of standards in reaching an accrediting decision 34 CFR 668.43 34 CFR 668.43 – Institutional Information 34 CFR 668.7134 CFR 668.71 – Misrepresentation Example of Michigan Colleges Online State Resource Chart: http://www.mccvlc.org/~staff/content.cfm?ID=282

15. wcet.wiche.edu WICHE Cooperative for Educational Technologies (WCET) www. http://wcet.wiche.edu/ www. http://wcet.wiche.edu/ The Analysis Resources:

16. wcet.wiche.edu State Authorization Network (SAN) www. http://wcet.wiche.edu/advance/state-authorization-network www. http://wcet.wiche.edu/advance/state-authorization-network The Analysis Resources:

17. wcet.wiche.edu State Higher Education Executive Officers Association (SHEEO) www.sheeo.org/sheeo_surveys/ www.sheeo.org/sheeo_surveys/ Example: The Analysis Resources:

18. wcet.wiche.edu State Authorization Compliance Strategy 2nd Step: Cost Benefit Analysis Considerations Institution considerations: 1.What are the out of state activity goals of the institution – which states? 2.Are the institution’s out of state activities covered by SARA? 3.What is the annual cost to the institution to seek required compliance as a Non-SARA institution? a. Fees (if any) in each state the institution’s activities are located 4. What is the annual cost to the institution to belong to SARA? a. National cost b. State cost c. Cost for compliance to Non-SARA states the where institution’s activities are located 5. What are the other variable costs? a. Staff time to manage research and reporting b. Cost to implement an oversight process if the institution chooses to restrict activities from certain states c. Ability to market programs out of state d. Number of students impacted

19. wcet.wiche.edu State Authorization Compliance Strategy 2nd Step: Cost Benefit Analysis You have to do the math! Chart and Calculate: (don’t forget to consider the variable costs!) NC- SARA annual fee + State SARA annual fee (if any) + Annual Fees to any desired Non-SARA states SARA Institution Costs VS. Summation of all annual state fees (if any) by all states that the institution participates in activities Non-SARA Institution Costs Photo credit: Open clip artOpen clip art

20. wcet.wiche.edu State Authorization Compliance Strategy 2nd Step: Cost Benefit Analysis Calculation example #1 Large Public Institution in Ohio with online and experiential activities in many states nationwide: SARA Member Costs: $6,000 – NC-SARA Fee for more than 10,000 FTE 6,000 – Ohio SARA Fee for more than 10,000 FTE 4,500 - Non-SARA state fees for activities in those states $16,500 – Total vs. Non-SARA member Costs: $48,500 – Total annual state fees for the institution’s out of state activities Compare: SARA Member Cost - $16,500 vs. $48,500 Non Member cost Scale tips to SARA!

21. wcet.wiche.edu State Authorization Compliance Strategy 2nd Step: Cost Benefit Analysis Calculation example #2 Small Private Institution in Oregon with 3000 FTE – Field Experiences only in border states SARA Member Costs: $4,000 – NC-SARA Fee for 2,500 – 9,999 FTE 2,500 – Oregon SARA Fee $5,000* biannual for 2,500 -9,999 FTE ___0 - No Non-SARA state fees required from the border states $6,500 – Total vs. Non-SARA member Costs: $2,500 – Total annual state fees for the institution’s out of state activities Compare: SARA Member Cost - $6,500 vs. $2,500 Non-SARA Member cost Scale tips to Non-SARA!

22. wcet.wiche.edu Common Area of Confusion #1 Military Students Most states do not distinguish between enrolling or recruiting students on military bases versus enrolling or recruiting others residing in a state. You must check each state’s regulations as there are some exceptions! (ex. Check: AK, GA, KY, NB, NH, NM, SC, WV)

23. wcet.wiche.edu Common Area of Confusion #2 Experiential Learning/Clinical Placements States define and regulate such placements in ways that vary widely. SARA covers many such placements for on-line as well as on the ground programs. You must check each state’s regulations as some regulate placements and you must read carefully the SARA definitions and rules regarding experiential learning.

24. wcet.wiche.edu Common Area of Confusion #3 Professional licensure programs and disclosures SARA does not cover professional licensure compliance requirements, but it does have disclosure requirements. USDE and accreditors also have disclosure requirements. Future USDE regulations might have even stricter requirements. You must seek approval and authorization with professional licensing boards in each state as always. Read the SARA professional licensure disclosure requirements.