In the last several weeks there have been several developments regarding state authorization of distance education courses and programs.  Here is a summary of those activities.

State Authorization Reciprocity Agreement
The four regional higher education compacts (Midwestern Higher Education Compact, New England Board of Higher Education, Southern Regional Education Board, and the Western Interstate Commission for Higher Education) are moving forward with implementing the agreement with financial help from Lumina Foundation.   Watch for a new website ( to be announced in the future with more information on reciprocity.

photo of Marshall Hill
Marshall Hill directs State Authorization Reciprocity Agreement (SARA) activities.

SARA Executive Director Named
Marshall Hill, former executive director of Nebraska’s Coordinating Commission for Postsecondary Education, assumes the post as the new executive director of the National Council for State Authorization Reciprocity Agreements (NC-SARA).   Marshall has been involved in all of the reciprocity efforts and is very knowledgeable on the issues.  He has had the regulatory role under his supervision in both Texas and Nebraska and is a long-time friend of WCET.  Marshall will provide steady, reasoned leadership.

NC-SARA Council is Announced
The members of the initial National Council for SARA have been announced.   Twenty-two were selected from more 80+ nominations.  The Council will: “oversee regional efforts to ensure that all SARA entities meet the expectations that have been established for reciprocity and will also establish common operating procedures.”  Members represent the state regulators, different higher education sectors, the four regional compacts, the accrediting community, and other interested constituencies.

Regional SARA Directors
Each of the four regions will have a director to organize SARA activities in their region.  MHEC recently named Jenny Parks as the director of the Midwestern State Authorization Reciprocity Agreement.  Mary Larson is currently handling these duties for both the SECRRA agreement and SARA.   NEBHE and WICHE are searching for directors.

The Department of Defense Proposes a New MOU Including a State Authorization Requirement
On August 14, the Department of Defense (DoD) published a proposed new rule that institutions offering education programs must meet if they wish to have their military students enjoy  DoD Tuition Assistance.  The rule is in a comment period with a deadline for comments of September 30, 2013.

One of the criteria proposed for the new Memorandum of Understanding (MOU) is that the institution must be in compliance with all Department of Education’s “program integrity issues, including State authorization.”  Regulation 600.9 is specifically cited.  Since 600.9(c) (the distance learning provision for state authorization) has been vacated by the courts, it is doubtful that they can enforce this regulation for distance education offered to students in other states.

While the DoD is interested in state authorization, it is good news for institutions that they did not decide to create their own rule.  That could only have further confused the issue.  This action by the DoD (relying on Education’s regulation) re-enforces our belief that the Department of Education will most likely bring back the federal regulation.

And What is the Status of Reinstating that ‘Vacated’ Department of Education Regulation?
This give us a chance to remind you that currently THERE IS NO FEDERAL DEADLINE for compliance with state authorization regulations.  Even so, the states still expect you to be in compliance prior to serving any students in their state…regardless of what the status of any federal regulation might be,

As you may recall, the federal regulation was ‘vacated’ by court order on procedural grounds.  The Department of Education can reinstate it by following notification rules that it did not use in introducing the regulation.  As to the future of  600.9c…in a chat with a Department of Education staffer, it was clear that:

a)      the Department would like to reinstate the regulation making it a federal requirement that institutions have authorization in each state in which it serves students.  Don’t forget that the Department took the first steps toward reinstating the regulation with its “negotiated rulemaking” announcement earlier this year.

b)      given the many holes in leadership at the Department (key positions remain unfilled) and the focus on the “gainful employment” rulemaking process, there is currently no clear timeline for moving forward.

We will continue to monitor and report on any progress made by the Department.Logo for the State Authorization Reciprocity Agreement (SARA)

State Authorization at the WCET Annual Meeting
At WCET’s Annual Meeting to be held in Denver, CO, there will be several sessions on Thursday November 14 regarding state authorization:

  • Marshall Hill, SARA executive director, will give an update on implementing SARA.  We hope to have all of the regional SARA directors in attendance, as well.
  • Sharyl Thompson, Southern New Hampshire University, and Pam Shay, Franklin University,  will give practical advice on how institutions can manage their authorization compliance processes from beginning to end.
  • Patricia Milner will have a poster session describing her research that examined influences on the adoption of polices that regulated the distance education operations of out-of-state, higher education institutions.

See you in Denver!!  Meanwhile, have fun complying with authorization regulations.


Russell Poulin
Deputy Director, Research and Analysis
WCET (WICHE Cooperative for Educational Technologies

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