SARA Update Spring 2015
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During the political campaign season, I personally approached my state representative about this issue and what may be happening in Kentucky. She didn't know what I was talking about. Where could I direct her for information relevant to state legislatures?
For specific's on where KY is with the SARA process, the KY SARA contact is Sarah Levy
Director of Postsecondary Licensing
Kentucky Council on Postsecondary Educa on
1024 Capital Center Drive, Suite 320
Frankfort, KY 40601
Phone: 502‐573‐1555 ext. 350
Email: [email protected]
How does the 35 state program affect dual credit at the high school level?
When an institution is approved by the state, how long does it take to be recognized by NC‐SARA?
Assuming that the work is college‐level, SARA covers any regulation imposed on this activity by the state's postsecondary regulatory agency. Colleges still have to meet any requirements imposed by the K‐12 school. SARA does not cover high school completion or similar work that does not result in a postsecondary award.
Once the institution pays the fee to NC SARA they are immediately recognized
Any word from states saying they don't plan to join SARA?
We know of no state that has said it will not join SARA.
Is Vermont fully approved? The website map says it is, but it has no date on the detail page?
The state application for Vermont has been received, but it still has to be reviewed and approved.
Iowa's legislature approved SARA, but Iowa's subsequent application to join SARA was Iowa's legislature approved SARA, but Iowa's subsequent rejected due to Iowa law prohibiting different requirements for for‐profit schools. Are we application to join SARA was rejected due to Iowa law the only state caught in this predicament? prohibiting different requirements for for‐profit schools. Will SARA include non‐degree institutions that issue certificates?
No.
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SARA Update Spring 2015
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Wisconsin is dealing with two situation which make it very difficult for them to move forward with SARA discssions at this time. First, they are deciding upon major reorganizations to their system of higher education. Second, they do not have a natural agency that could act as a portal agency. There are on‐going dicussions among the hihgher education leaders in the state about joining SARA, We were told by WI that they have chosen NOT to join SARA. That was last spring. Have but such discussion necessarily have taken a back sear to the they reconsidered? We just talked to their rep 2 weeks ago and he did not indicate that. more pressing issues they are facing currently.
Jennifer: do you anticipate the change in governorship in IL to slow down the SARA I have not heard anything that would make me think that process?
there will be a slow‐down in the IL SARA process.
Is the state institutional fee only for institutions located in the state or for institutions out SARA insituions will only pay participation fees to their of state?
home state (if required) and NC‐SARA.
This was covered in the second half of the webinar. A data collection and submission guide is forthcoming this summer to help SARA participating institutions provide data to NC‐
SARA.
Will anyone be talking about the reporting requirements that start in April?
Mississippi has introduce legislation and is going though the state process. What is the actual status in MS? MS Commission on College Accreditation is expected to be the portal agency, right?
Discussion regarding SARA Participation in Mississippi are still ongoing. At this time, no decision has been made regarding the SARA State Portal Agency.
For clarification, there will always be a NC ‐SARA fee plus additional fees on a state‐by‐
state basis. Is this correct? Yes, there will be an NC‐SARA fee. States decide whether to have their own fee. Some do, some don't.
Currently DC is the only territory that is actively pursuing a relationship for SARA purposes with any of the regional compacts. 2015 if the legislation passes this year ‐ it may be September but 2015 is the "plan"
Is D.C. the only district or territory discussing participating?
Is Texas anticipated in 2015 or 2016?
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SARA Update Spring 2015
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Is SARA going to push SARA state institutions in any way? number. Will we have to apply through two different states' SARA portals in order to offer online education across the US? Our University's two campuses are accredited as one institution by HLC.
Answered
I am not sure what you mean. Can you contact me soon so that we clarify? Jenny, [email protected]
the same state, it will use that state as its home state. Other campuses sharing that accreditation but having their own OPE numbers will be treated as branches. If there is no The status of Maryland changed while we were on the webinar. Can you describe where the state of Maryland is now in the SARA‐joining process please.
In the webinar, the phrase "a student being in Illinois" was used? What exactly are we supposed to define as an out of state student and where that student is "from"? Live? Study from?
Maryland has introduced legislation but it has not been signed by the Gov.
Are SARA states allowed more leeway in advertising in other SARA states without triggering presence? Yes, advertising is one of the activities that is covered by the SARA agreement and its Policies and Standards.
What matters for purposes of SARA is where the student is physically located while enrolled. We've heard two answers on that: 1) that DoD is waiting for the new 600.9(c); 2) that they are going ahead since they expect you to follow state laws. At recent meetings, most colleges were proceeding with the understanding that DoD wants them to be in compliance now. With that being said, it is enforceable because the language bases it on "being consistent" with 600.9 and that institutons must "meet all Russ, since 600.9(c) was vacated; is the DoD MOU enforceable without regulations issued state laws". Since the state laws were not vacated, it should be enforceable.
by the ED?
So, physical placement is covered under SARA in all SARA states? SARA covers supervised field experiences, including clinicals, student teachers etc. in other SARA states, whether or not the PROGRAM is online. SARA also covers 20 hour short courses and 6 hours of face to face time between students and instructors per academic term.
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SARA Update Spring 2015
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What is the definition of "per site?" For example, a hospital may accept students on rotation in the pharmacy department, on the internal medicine service, in the nursing department, etc. So, if a University intends to send students from its medical school to the internal medicine service, ER service, and GI service. Can it send 30 students to the 3 Yes, if the degree being earned by the student is different, different rotation sites within the same hospital?
as these three would be.
Regarding the 10 student limit, is that only for sites outside of your state? For instance, if you have a site in your state that currently accepts 30+ students, is that affected?
SARA only covers out of state activity.
What will count as "enrollments"? Student's home state based on residency?
Please wait for the forthcoming data guide.
Enrollment data will be reported by state. NC‐SARA will report SARA state enrollments separately and non‐SARA states in aggregate.
To clarify, the data for non‐SARA states is aggregate or by individual non‐SARA state?
If what you are asking is a SARA instituion doesn't have to ask for permission for on site clinicals to take place in another SARA state, then you are correct. More information can be found in the policies and standards section 5 (3) http://www.nc‐
If you are an institution in a SARA state, you do not have to apply for permission for on sara.org/files/docs/FINAL%20SARA%20General%20Policies%
20released.pdf
site clinicals? In another SARA state? The Department of Education has the SARA language. It is likely that the Department may go in a slightly different way. They are certainily very interested in the disclosure issue, as Any chance any fed. reg. prof. licensure disclosure/notification requirement will mirror they added language on disculosure for professional licensure programs to the Gainful Employment regulations. SARA standards options? Believe proposed rule required notification of specific state licensing board requirements...i.e. SARA standard option B would not have worked under If the new federal regulation differs from what SARA has, SARA will most likely adjust to align the requirements.
the proposed ('on hold") regulation.
which state was not willing to say that an online program does/does not meet licensure The case I am aware of was the Oregon Board of requirements?
Psychology.
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SARA Update Spring 2015
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Should we place the licensure disclaimer on our website?
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Yes. what is the definition of a program that leads to licensure? Is it only programs where the license is automatically conferred upon successful completion, or does it include We generally use a broad definition of anything that is programs like nursing programs, where a further exam is still required.
intended to lead to a license by the state. I don't know. In general students take action against colleges, not licensing boards. It is hard to win a case against a professional board that is applying its own standards.
Has anyone ever sued a state on not being able to be licensed? SARA‐enabling legislation has been introduced in the 2015 legislative session. SB108 and HB762. The Pennsylvania Department of Higher Educa on will be the portal agency.
Could you please repeat the status for Pennsylvania? I was not aware there legislation introduced
We need to work on this issue and clarify it. At a minimum, the information has to be provided if a student pays the In regards to slides 44 and 45 (professional licensure disclosures), do you do this when school any money. Ideally it should be provided as early as the student applies to the licensure program or after the student is accepted and possible.
admitted into the program?
RE Professional Licensure: Can "notification" simply include posting on University websites and enrollment materials? Or, should institutions request a signed disclosure SARA does not require a signed statement. There are some statement from the student?
advantages to having one.
If you are an institution in SARA State A wishing to place more than 10 students from the same program in the same With regards to Supervised Field Experiences which portal agency should the institution site in a supervised field experience in SARA State B, you request additional approval/authorization for additional students to complete their field need to seek the approval to do so from the portal agency of SARA State B.
experiences/clinicals?
If a institution wants to comply with multiple states outside of its home state and SARA region, do they have to apply to each SARA region, or to one state in each region? Please Once an instituion is approved as a SARA instiution, they are advise.
cleared to operate in any SARA state. How does Program Integrity impact international students? SARA has no relationship to students residing and taking classes from US institutions while located outside the US.
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SARA Update Spring 2015
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Will the recording of the non SARA IPEDS information by institution name not cause some issues with the institutions that don't have approval in the non SARA states?
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Yes. Please contact your regional SARA director. Contact information can be found at http://www.nc‐
sara.org/content/sara‐staff
Yes
That's why non‐SARA state enrollments will be reported by NC‐SARA in aggregate. Only SARA state enrollments will be reported by state.
Is possible to provide any more granular breakdown of the numbers of institutions par cipa ng? I also did not hear for‐profit ins tu ons men oned in the list. Has there been any interest there? And is there any sense of a breakdown for regionally and nationally accredited institutions? Thank you! We'll work on this and report what we can through our blog.
Where can I find contact information for a state to inquire about legislation in a state? Would I directly contact the regional director or is there a more appropriate contact? Does SARA cover recruitment in admission and athletics?
WCET's State Authorization Network is a separate initiative that is entering its fifth year of operation. SARA is in its second year. SARA is an interstate agreement that facilitates the authorization of instituitons that cross state lines. SAN is a network of instituitons who are seeking compliance. We share information about the best way to seek compliance. Even if SARA were to cover every state, it does not cover licensure issues. SAN and SARA work hand‐
in‐hand to support each other. My institution just forwarded me an email on WCET‐State Authorization Network. Is this http://wcet.wiche.edu/advance/state‐authorization‐
network
connected with SARA or a separate initiative?
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SARA Update Spring 2015
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Can someone talk more about field experiences. Do universities need to focus on authorization for non‐online programs sending students out for field experience?
What is SARA's role in the transfer of credit?
Does SARA help non‐SARA participating states/institutions? Are the two fees annual or a one time fee?
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Colleges and universities always need to find out if their placements of students in clinical field experiences in other states constitute activities that are regulated by that state. In the case of two SARA states, however, the school sending the students to a field placement in the second state does not have to check with the higher education authorizing entity in the second state unless the number of students in the field placements exceeds tend students per site per program. In such cases, the sending institution needs to make the SARA portal agency of the receiving state aware of this and seek permission to exceed the limits described above. SARA has no effect on transfer of credit.
Hard to know what is meant by "help." We provide information, will be good neighbors, will try to do what we can, etc.
NC‐SARA fees are annual; to my knowledge, state fees are, too.
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SARA Update Spring 2015
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Some states regulate residential students who return home for the summer and take on‐line courses from their residential university just like the state regulates all interstate on‐line education. If yours is a SARA state, the students returning home and taking on‐line courses in the summer are fine as long as they go home to another SARA state. Those who do not go home to another SARA state and who wish to take on‐line summer courses will need to be treated and authorization/exemption/regulation/registration will need What about traditional onsite students who take classes during the summer. Do we have to be sought in those states under the traditional system of state authorization.
to have authorization for the state they live in during the summer?
What is the best mechanism for tracking "physical location?"
Developing a consistent and rational policy for colleting this information is sufficient. Some institutions are asking each term in which the student registers for classes. How does SARA hiring affect off‐site hiring of faculty?
I believe you are asking about adjunct, on‐line faculty who live in a state other than the one in which the institution is located. If so, then, yes, SARA covers that activity, if all the states involved are SARA member states.
(follow‐up: if what counts is where a student is physically located while receiving (online) instruction, then not sure that IPEDS data would be applicable, right?
Please wait for the forthcoming data guide.
Am I correct in understanding that the state fee is charged only to the institutions within that state who wish to be part of SARA in that state?
Correct.
When reporting number of online students do we need to count those in online programs only or does this include students taking single online courses?
All students.
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SARA Update Spring 2015
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Will the yearly reporting relieve participating institutions from being required to report data directly to a (any) state?
Does SARA require the registration of agents? some states not a member of SARA, do require that some staff/recruiters apply to become "registered agents"
Annual reporting to NC‐SARA will replace reports to SARA states; non‐SARA states' requirements will remain.
SARA covers recruiters and other institutional agents operating in other states under the rules of education agencies. SARA does not cover a state's general purpose business license or registry that would be applicable to all nondomestic entities.
If an institution chooses to exclude students from a specific state, to what extent is an institution required to prevent students within that state from enrolling at the institution? What liability does an institution incur?
The liability question goes to the institution's legal counsel. If an institution decides not to enroll students from a specific state, then presumably the institution accepts the consequences of failing to follow its own policy.
We have quite a few military students enrolled at UCM, is there an exception for this specific situation if the student is permanently relocated to another state (non‐SARA state)?
No. If the military person goes to a non‐SARA state, the military person in question is subject to the regulations of that state. A few states exempt military bases/posts, but it is up to each state. We are working on this, but it will take time.
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SARA Update Spring 2015
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No. We are trying to keep the reporting streamlined and Is there any sense of the relative enrollments of first‐time and not‐first‐time students in minimal so that it is not a burden to participating the distance programs that will be made available throughout the SARA network?
institutions.
If a student enrolls at an institution that is a member of SARA, then relocates to a non‐
SARA state, is the institution still responsible for seeking that State Authorization?
Yes. Didn't really answer my question. If an online student in a state where an institution is authorized MOVES to a state that the institution is NOT authorized in, how can the institution continue to provide for that student since it is NOT authorized to educate students residing in that State? Again, this is a Wisconsin problem, since Wisconsin is not part of SARA and has very comprehensive state authorization rules.
You would have to contact WI EAB and ask how they would want you to handle that one student. In most cases, the regulators are pretty helpful and will work with you when it is just one student who has made substantial progress through your program.
Annual data reporting will occur via a on‐line submission and go straight to NC‐SARA. All the institution provides to the portal agency is its initial and renewal applications unless Is the institution providing this information to its portal agency and passed on to NC‐
SARA or do the institutions have to submit reports to both its portal agency, if requested, otherwise specifically asked for other information by the portal agency.
and NC‐SARA? Is there a cap SARA states can charge?
No, each state may charge what they think is necessary
If an institution in state A is pursuing authorization in a non‐SARA member state B, what happens to fees paid to state B if that state then becomes a member of SARA soon after the fees are paid? How should an institution proceed?
SARA requires no refunds.
SARA states are reviewed by their regional steering committee every two years and SARA institutions are reviewed and undergo a simple renewal process by their What is the term of SARA approval between states? One year, two years, three years? state portal agency once a year.
SARA does not distinguish among types of academic evaluation. That's up to the provider. So yes, CBE is Does SARA cover competency based education (CBE) online programs?
covered if it is otherwise SARA‐eligible.
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SARA Update Spring 2015
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What is the most current data posted on IPEDS?
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Fall 2013
Institutions are assumed to know the geographic location of their U.S. students. We recognize that there are many situations in which a student might be moving here and there. Because state laws cover what happens inside their borders, SARA has to follow the same model.
Could please elaborate more on residency requirement? If the residency is not considered, but SARA looks at a place from where a student takes instruction from, will institutions be enforced to monitor where students log in from? If an institution began the process of seeking approval to operate in a SARA state prior to becoming a SARA institution, how should the institution proceed after it becomes a SARA institution? Notify the affected host state of the change in status.
We are actually looking at starting to collect some of those resources, but we don't have anything ready for you yet. Where would we find information regarding other country's regulations?
Still working on problematic details like that. The data If a student is a resident of State A, attends class in State B and participates in a clinical reporting manual will attempt to resolve such issues, but the practicum for credit in State C, which states are reported in the SARA enrollment report? many, many patterns
Can a student pursue a complaint up through the portal agency as well as the state attorney general's office (or state consumer protection agency) in the SARA state?
Nothing in SARA precludes a student from complaining to anyone, including President Obama. More realistically, students should complain to the offering institution, then the institution's SARA portal agency. On matters of fraud and violation of general consumer protection laws, students can also contact their or the institution's state AG or consumer protection agency.
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SARA Update Spring 2015
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Can you comment on schools in MN and typically at what staffing level or department are you seeing higher ed institutions "house" the work to apply to the state portal?
I think you are asking how much time and staff it takes to have folks at the institutional level take care of all their state authorization work. This will depend on the number of states in which the institution is engaging in educational activities, what types of activities those are, and how many programs are offered in those states. For all these activities in SARA states, it is one easy application that can be downloaded from the NC‐SARA website and completed in its first draft in about fifteen minutes. Depending upon how easily you can lay your hands on the supporting documents, explain the documents and the system to an institutional executive, and get her/his signature, the whole process could theoretically take less than an hour for the SARA application.
For the quarterly reporting of out‐of‐state students that institutions are required to report on, will that be sent to the state portal agency? Will the state portal agencies send us notifications that information is due?
Will non‐SARA state educational agencies have access to individual institutional enrollment reports?
I thought one of the major functions of the state portal agency is to be a collector and repository for all of these data. Then the state portal agency would be responsible for reporting forward. Some confusion here. SARA institutions will report their enrollments once per year to NC‐SARA, not to their state portal agency. NC‐SARA will provide a data reporting manual and e‐mail notices well before enrollment reports are due. The quarterly reporting, done by the state portal agencies, is of appealed complaints.
No. Not unless directed by a court.
No, that's not the case. Many states told us that collecting enrollment data for their SARA institutions would be burdensome, so it was decided that NC‐SARA would handle that. States will keep track, and then report to NC‐SARA, data on complaints appealed to them.
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SARA Update Spring 2015
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How are institutions locating online students who move out of state and do not notify the institution?
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An institution can only report on information it has. If an institution has a policy and a system that checks on students' self‐reported location according to a logical and reasonable time frame, that is all that is necessary for them to track.
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