State Authorization: Reciprocity Update, New Military Rules, and New Survey
Published by: Russ Poulin | 11/20/2012
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.
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.
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.
Deputy Director, Research & Analysis (& Turkey)