About NC-SARA

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National Council of State Authorization of Reciprocity Agreements (NC-SARA)

The State Authorization Reciprocity Agreements, commonly known as SARA, provides a voluntary, regional approach to state oversight of postsecondary distance education.  When states join SARA, they agree to follow uniform processes for approving their eligible institutions' participation.  They also agree to deal with other states' SARA institutions in a common way when those institutions carry out activities in SARA states other than their own.

SARA's policies help protect students and provide benefits to both states and institutions carrying out distance education in multiple states.  As of July 2019, 49 states, the District of Columbia, Puerto Rico and the U.S. Virgin Islands are members of SARA.  About 1,993 colleges and universities.

The Evolution of SARA

Each step of SARA’s evolution required a great deal of conversation and a lot of debate. The people involved came from various perspectives, including: state regulators, state higher education executive officers (SHEEOs), accrediting organizations, regional higher education compacts, and institutional leaders representing all sectors of higher education. While SARA is certainly not a federal initiative, we appreciate the opportunities we have had to consult with supportive leadership of the U.S. Department of Education during SARA's development.

  • Lumina Foundation provided funding to the Presidents’ Forum, working with the Council of State Governments (CSG), to develop a Model State Authorization Reciprocity Agreement (SARA) that states could adopt to acknowledge other states’ work and decisions in regard to institutional authorization.
  • Building upon the work of the Presidents’ Forum and CSG, the Western Interstate Commission for Higher Education (WICHE) advanced “W-SARA” in collaboration with the regional higher education compacts (Midwestern Higher Education Compact, New England Board of Higher Education and Southern Regional Education Board). Similar documents were produced by the other three regional compacts.
  • Combining all prior efforts and input from all stakeholders, in April 2013 the Commission on the Regulation of Postsecondary Distance Education, founded by SHEEO and The Association of Public and Land-grant Universities, and chaired by former Secretary of Education Richard W. Riley, issued its report: “Advancing Access through Regulatory Reform: Findings, Principles, and Recommendations for the State Authorization Reciprocity.
  • In August 2013, Lumina Foundation provided $2.3 million in funding for regional and national implementation. The National Council for State Authorization Reciprocity Agreements (NC-SARA) was established, and regional and national SARA staff began work. In July 2014, Lumina Foundation provided additional funds to total $3 million for implementation of the initiative.
  • In November 2014, the Bill & Melinda Gates Foundation provided $200,000 to fund the effort.
  • In January 2014, the higher education compacts began inviting states in their region to participate in SARA.

SARA was developed with input from:

  • A broad advisory committee
  • Regional higher education compacts (MHEC, NEBHE, SREB, WICHE)
  • State regulators
  • State Higher Education Executive Officers (SHEEOs)
  • Accrediting organizations
  • U.S. Department of Education
  • Institutional leaders representing all sectors of higher education

Key Attributes of SARA

  • Acknowledges the traditional roles within higher education’s “accountability triad”: federal government, states, and accrediting bodies recognized by the U.S. Department of Education.
  • Lays out a framework for state-level reciprocity, including a governance structure, implementation by the four regional higher education compacts (MHEC, NEBHE, SREB, WICHE), a National Council for SARA to ensure comprehensive national coverage, and a financial plan to support operations.
  • Requires states to approve their in-state institutions for SARA participation (based upon institutional accreditation and financial stability) and resolve student complaints.
  • SARA states agree to impose no additional (non-SARA) requirements on institutions from other SARA states.
  • Open to degree-granting postsecondary institutions from all sectors: public colleges and universities; independent institutions, both non-profit and for-profit.
  • Participating institutions will agree to follow the Interregional Guidelines for the Evaluation of Distance Education Programs (Online Learning) for best practices in postsecondary distance education developed by leading practitioners of distance education and adopted by the Council of Regional Accrediting Commissions (C-RAC).
  • Sets forth a reasonable, uniform set of triggers of “physical presence.”
  • Preserves state approval and oversight of on-the-ground campuses.
  • Shifts principal oversight responsibilities from the state in which the distance education is being received to the “home state” of the institution offering the instruction. The host state (where the student resides) can also work to resolve problems.
  • Initial funding from Lumina Foundation and additional funding from the Bill & Melinda Gates Foundation, eventual reliance on institutional fees paid to the National Council for SARA.

Issues SARA does not address

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 those issues were resolved would, in our view, have delayed 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.). And while SARA does not deal in detail with non-credit instruction, if an institution participates in SARA, its for-credit and non-credit activities in SARA states are covered by the agreement.

Key Takeaways

SARA is voluntary for states and institutions.

SARA is administered by the four regional education compacts (Midwestern Higher Education Compact, New England Board of Higher Education, Southern Regional Education Board, and the Western Interstate Commission for Higher Education), they are now accepting applications from states in their regions. Once states are approved, they can begin to enroll eligible institutions.

Membership is open to degree-granting postsecondary institutions from all sectors (public colleges and universities; independent institutions, both non-profit and for-profit) accredited by an agency recognized by the U.S. Secretary of Education.

Shepherding Change: Creating the State Authorization Reciprocity Agreement (SARA)

Paul H. Shiffman and James W. Hall. "Shepherding Change: Creating the State Authorization Reciprocity Agreement (SARA)."
Available in: John Ebersole and William Patrick (Eds.) Learning at the Speed of Light.
Albany, New York: Hudson Whitman/Excelsior College Press. 2017, p. 369 – 397.
Used with the permission of the publisher. All rights reserved.