The work on the State Authorization Reciprocity Agreement is moving forward and I’m inviting you to give some feedback.  Additionally, significant new rules regarding state authorization for military personnel are on the near horizon.  For those waiting for state authorization to “go away,” they may not be too happy. Finally, we’re updating our survey on what colleges are doing regarding compliance and we need your help.

Reciprocity Update

For people asking “ain’t this done yet,” I need to assure you that the State Authorization Reciprocity Agreement (SARA) is one of the most difficult and most political tasks that I have ever seen.  Here’s a brief status on what the different players are doing:

The Presidents’ Forum

The Presidents’ Forum of Excelsior College received a grant from Lumina Foundation to create a model agreement for interstate reciprocity regarding state authorization.  They have been working on this issue prior to the release of the federal regulation in October 2010.  Their most recent draft of this model agreement is available online.  They will complete it soon after some discussions with the regional higher education compacts to work on some details.

A picture of a man's hand and woman's hand involved in a handshake.
The State Authorization Reciprocity Agreement is moving forward, but it is more than a handshake agreement.

The Regional Higher Education Compacts

These organizations (MHEC, NEBHE, SREB, WICHE) have been around for decades forging higher education agreements among states within their regions.  Since the Presidents’ Forum is creating a model and is not implementing their draft, the four regions are working on an implementation version of SARA that will cover all states and territories.  Like the Presidents’ Forum model, states will individually have to choose to join the agreement.  Beginning early in 2012 and based on the Presidents’ Forum model, WICHE took the lead and created an implementation draft that is now being reviewed by the other regions.  MHEC and NEBHE have held meetings giving positive and constructive feedback. SREB’s meeting is upcoming.

The Commission on Regulation of Postsecondary Distance Education

Created by the Association of Public and Land-grant Universities (APLU) and the State Higher Education Executive Officers (SHEEO), the Commission had an organizational meeting in May and discussed reciprocity at a September meeting.  Their current draft of recommendations leans heavily on reciprocity work that preceded it, but suggests some changes.

REQUEST OF YOU:  We’d love your comments, but the time is short.  I’m going to try to get a link to their recommendations posted to this blog soon.  Meanwhile, you can email me if you want a copy of the Commission’s recommendations.  Get your comments to me by the end of the day on Tuesday, November 27.  I know this is short, but the Commission is trying to meet a short timeline.

New Military Rules

Thank you to our friends at the Dow Lohnes law firm, I’m hearing that the Department of Defense will be issuing a new Memorandum of Understanding for institutions that serve those in the military.  One provision of this new agreement will be that institutions will need to demonstrate that they have authorization, if needed, to serve military personnel in the state in which she is receiving the instruction.  The regulation appears to be based on the vacated 600.9(c) regulation.

Even institutions that are not part of the Servicemembers’ Opportunity College (SOC) program will need to sign the agreement if they are serving military personnel.  There will be a comment period once the proposed MOU is released.  We will let you know when the Memorandum of Understanding is released.

State Authorization  “What are Colleges Doing (or Not Doing)” Survey

We are constantly asked “what are other institutions doing about state authorization?”  Are they waiting?  Are they moving forward?  We need data and we need your help.

WCET has again partnered with UPCEA to update last year’s survey on the state of institutional compliance with state authorization regulations.  Joining us as a partner this year is the Sloan-Consortium.   The survey is now out and went to only one person at each institution.  Where we had multiple contacts across the membership lists of the three organizations, we had a formula for deciding on which name to use.  However, the formula was not perfect in identifying the right person in each case.  The survey was sent out by Jim Fong of UPCEA. If you did not receive it, check with others at your institution and check your spam filter, as someone has already found one there.

If no one at your institution received it and you would like to participate, email me with your name, institution, and email address and we will get you a survey invite.

Thank you for your help.Photo of Russ Poulin


Russell Poulin
Deputy Director, Research & Analysis (& Turkey)

1 reply on “State Authorization: Reciprocity Update, New Military Rules, and New Survey”

As a member of the Forum/CSG working group for the past two years, I’d like to thank Russ for his extraordinary service. He is quite right, the question of state authorization and how to improve it is exceptionally complex. Anyone who has a “simple” solution has no solution; unfortunately simple solutions are popular.

Just one example: a large state with many institutions, public and private, may want to participate in interstate reciprocity. Let’s assume its educational leaders all agree and they are ready to sign off. They can’t.

Why not? Because their state has a law prohibiting the state’s consumer protection fund from being used to benefit anyone who is not a resident of that state. So the state is ineligible until that law is changed to allow those funds to be paid out to distance-ed students clear across the country.

This is just one example of the many issues that the people implementing the SARA plan must deal with. Another “simple” fix? Maybe. Maybe not.

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