State Authorization: What is a Supervised Field Experience and Where is it Regulated?
April 2015, Updated May 2017
Although more and more institutions are aware of state authorization and its triggers, there continues to be a great deal of confusion and misunderstanding. Often, people want a cut and dried, yes or no answer so decisions can be made. However, anyone who has worked in state authorization for any length of time knows this just doesn’t exist. Seldom is it simple; seldom is it black and white. That’s why the mantra for state authorization is, “it depends”. A great example of this is if and how supervised field experiences are triggers for authorization in the states.
That brings up the first issue – terminology. What is a supervised field experience? That depends! For purposes of this writing, “supervised field experience” will be the term used generically for any activity such as internship, externship, practicum, student teaching, clinical, clerkship, etc. Ultimately, it does not matter what the institution calls these experiences; that is not what determines if it is regulated. Sometimes institutions try to be creative in what they call a supervised field experience thinking that removes the trigger for needing authorization. The truth is, it is the activity itself that determines if it is a trigger. And the triggering activity(ies) vary from state to state.
Differences in State Regulations
Many state regulations require authorization of an institution before its students do a supervised field experience within that state. This is where the simplicity ends. There are many different conditions to consider when evaluating whether or not a supervised field experience triggers the need for authorization. The list below is not necessarily all-inclusive, but the factors for consideration may apply in the three remaining non-SARA states, and do apply for any non-SARA institution. At the two opposite ends are, (1) all supervised field experiences are allowed – no authorization required; and, (2) no supervised field experiences are allowed without authorization. Between those two are the following nuances:
- All internships are allowed, but the state needs to be notified of such activity
- No internships are allowed, but an exemption is possible
- Religious or pastoral internships may not be regulated
- If institutional instructor does or does not direct the supervised field experience
- If the site supervisor is paid or not paid
- The state determines on a case-by-case basis if authorization is required
- If the supervised field experience is required or optional
- If the supervised field experience is credit-bearing (vs. carries no academic credit)
- If the supervised experience is part of a campus-based program or an online program
- If the site and supervisor is found independently by the student
- If the supervised field experience is organized by the student or by the institution
What About SARA and the Internship Trigger?
SARA reduces the regulatory burden for institutions, including the supervised field experience activities across state lines. It is important to remember that the SARA standards only apply in states that are members of SARA. So, institutions approved to participate in SARA still need to comply with the state authorization regulations (like supervised field experiences) in any of the non-SARA states. The SARA General Policies provides this definition:
“Supervised field experience” means: a student learning experience under the oversight of a supervisor, mentor, faculty member or other qualified professional, located in the host state, who has a direct or indirect reporting responsibility to the institution where the student is enrolled, whether or not credit is granted. Examples include practica, student teaching, or internships. Independent off-campus study by individual students not engaged in a supervised field experience is exempt from requirements of this compact and does not constitute a physical presence of a postsecondary institution in a SARA member state.”
Under SARA, an institution may not place “more than ten students for an individual academic program simultaneously at one clinical or practicum site, unless approval for a larger number is provided by the host state SARA portal agency.” http://nc-sara.org/content/sara-manual
So, once an institution is approved to participate in SARA, it needs to track how many students in an academic program are doing a supervised field experience in another state. The limit is ten students in the same program at the same site at the same time, unless an exception is granted. And as mentioned earlier, the institution needs to proactively allow or not allow students to do supervised field experiences in non-SARA states, depending on the individual state regulations.
Supervised Field Experiences for Licensure-Track Programs
If an institution offers any program that leads to a professional license (such as, nursing, education, CPA, counseling, psychology, social work, etc.), there are additional regulations regarding field experiences. State professional licensing boards often have requirements for how many hours, the type of location, the qualifications of the site supervisor, and the competencies that must be included in the supervised field experiences. These regulations are completely separate from the state authorization regulations; yet, some state authorization regulatory agencies may require institutions to have their licensure-track programs reviewed by the state’s professional licensing board before authorization will be granted.
These intersections of state authorization regulations and professional licensing board regulations are presented in more detail in two previous papers written by this author: State Authorization and Professional Licensure and Institutional Disclosures Regarding State Authorization and Professional Licensure.
So where does an institution go from here? First, SARA institutions should follow the guidelines above. If an institution is not a SARA participant, it is important to carefully research state authorization regulations (including definitions) alongside having a clear understanding of all of the supervised field experiences students are or may be doing in the future, and where. By comparing what the state regulations say with the activities the students are participating in, the institution can then determine if it will seek authorization in states where they currently don’t have it or if it will notify students of those states where they cannot complete the supervised field experience.
Sharyl J. Thompson
CEO, Higher Education Regulatory (HER) Consulting
Sharyl Thompson is the CEO of HER Consulting located in Minneapolis, MN. Sharyl started her career in higher education regulatory affairs over 15 years ago. She was a member of the original Drafting Team that laid the groundwork for the current SARA. She has written a number of articles, presented at numerous conferences, and most recently contributed to the authorship of “State Authorization of Colleges and Universities”, now available on Amazon. Sharyl currently consults with institutions in all sectors in matters concerning state authorization, professional licensure, state-by-state research, and accreditation.