State Authorization & Supervised Field Experiences: Easier Than You Think

We welcome guest blogger Alan Contreras who is a former regulator for the state of Oregon and is the chief interpreter (not his official title) for all the details of how states and colleges are implementing SARA (the State Authorization Reciprocity Agreement) in their own settings. SARA allows some field experiences (face-to-face clinical, practica, interships and the like) in other states. Alan guides us through some misconceptions and misdirection that he has encountered. He reminds us of our own “Dear Abby” giving us advice on our authorization troubles.
Russ Poulin

In recent months as SARA has grown and states grapple with complexities in supervised field experiences, I have encountered a few cases that give rise to the need for some explanation.

Nervous in New Jersey: A Parent Gets Bum Info about a Clinical Placement
First, even if a state regulates most on-ground activities, it might not regulate clinicals or other field experiences.  A recent case involved a college in Virginia simply assuming that it could not place a student in a clinical site in New Jersey because New Jersey had not yet joined SARA.  Setting aside for the moment the question of what SARA does and doesn’t do, the school made a mess that it did not need to.  The student’s distraught parent called me.  The parent was in New Jersey and the conversation went something like this:

Parent: “how can our family suddenly be expected to pay for our daughter to do a clinical far from home; she planned to stay with us.”

Me: “Where do you live?”

Parent: “New Jersey.”

Me: “Why can’t the college place a student at a clinical site in New Jersey?”

Parent: “SARA doesn’t allow it.”

Me [grinding teeth and silently whispering ‘boolsheet’]: “When does your daughter’s internship start?”

Parent: “In June.”

At this point there were clearly several problems with what the school had done.  First, it had told the parent that SARA “prohibited” the student from being placed in a non-SARA state [boolsheet].  Second, it assumed that New Jersey regulates clinical placements without asking the state.  Finally, it assumed that New Jersey would not be in SARA by June, 2016.

Two of these were demonstrably wrong—I had seen the New Jersey rules the previous month—and the third was almost certainly wrong. SARA does not “prohibit” states from placing students anywhere they like.  The institution had chosen not to place students in non-SARA states because it was inconvenient or potentially expensive.

But was it inconvenient or expensive in New Jersey?  No.  The state doesn’t regulate most supervised field experiences.  The school hadn’t bothered to find out.  Finally, the school had also never asked New Jersey when it was joining SARA.  The answer is that the state is almost ready to apply and we’d be astonished if it isn’t a member by June.

I briefly explained to the parent that the school was mistaken about what SARA did and decided that the way to achieve universal bliss was to ask the extremely capable and practical licensing officer in New Jersey to talk to (a) the parent and (b) the school.  He did so, fixed the problem for the student, and I had a call from the parent a few days later saying “I love you!”  Well, now, that’s pretty good for twenty minutes’ work from three time zones away.

Krazy in Kentucky: Army Student Initially Refused a Field Placement
We had a similar case arise in which a Virginia college (something in the water?) refused to place a pharmacy student at the U.S. Army base at Fort Campbell, Kentucky because of the well-known stiffness of Kentucky regulations.  That e-mail conversation went kind of like this:

Student: “the school says that Kentucky isn’t in SARA and they don’t want to brave the unspeakable horror of the Kentucky regulations.” [ok, he didn’t say “unspeakable horror,” that’s my gloss]

Me: “Did the school ask Kentucky if it regulates activity on military bases?”

Student: “I don’t know. The base crosses a state line but the mailing address is Kentucky so….”

At this point I copied the conversation to the also very capable Kentucky licensing officer, who replied the same day explaining how Kentucky law worked and that a clinical placement of this nature onto a military base was NOT regulated by the state.  Not much horror to be found there after all, if one phone call had been made.

The lesson: some situations, even in high-regulation states, are not the swamps full of R.O.U.S. that they seem to be.  If you want to help your students, make a couple of phone calls.  Hand out some help, get some love.

It’s the College that Decides Where to Obtain Authorization
Finally, those of us who work for SARA are becoming weary of the unfortunate sounds made by those colleges that tell students: “SARA doesn’t allow us to place students in your state.”

Nonsense.

This is simply a cover for schools that don’t choose to engage in proper state authorization and prefer to blame it on SARA rather than own their own decisions.  SARA is not perfect and we are happy to own what we do (and fix what needs fixing), but if a college chooses not to operate in a non-SARA state, we’d appreciate it if the school tells the students the real reason why.

Alan Contreras, J.D.
SARA Coordinator
acontreras@nc-sara.org

“Confused” Photo Credit: Brian Talbot