SAN Releases a New “How To” Handbook to Build an Institution’s State-to-State Authorization Plan

The other important SAN reports include:

• The Evolution of Compliance for State Authorization of Distance Education, By Sharyl Thompson (2023).
• Professional Licensure Requirements Handbook 2nd edition (2024).

The newest report, State to State Institutional Approval for Distance Education Handbook, walks institutional teams through building a practical compliance plan to obtain any required state approvals to serve students located in other states.

• Who it’s for: Institutions operating outside of reciprocity policy provided through the State Authorization Reciprocity Agreements (SARA).
• Why now? The project was prioritized to support SAN’s ~200 California member institutions, since California is not a SARA member state.
• Helpful even if the institution participates in SARA: SARA-participating institutions will gain a deeper understanding of state-to-state nuances and the sometimes-dense nature of authorization, even when much of their out-of-state activities are authorized through the policies of the reciprocity agreement.

Today on Frontiers, we are pleased to welcome back Shari Miller to share a concise summary of the handbook and the compliance road it maps.

Shari is a long-time colleague and friend of SAN. She led state authorization work before and after the development of reciprocity through SARA at the institutional level. Shari now consults with a wide range of institutions, including those not participating in SARA, on authorization strategy, operations, and documentation. Shari also authored SAN’s Professional Licensure Requirements Handbook (1st and 2nd editions), mentored cohorts in SAN’s Basics Workshop for many years, and is a frequent SAN presenter and contributor. You’ll find her full bio at the end of this post.

Get the Handbook and Put it to Work

• Download it: State-to-State Institutional Approval for Distance Education Handbook
• Pair it with: Getting Started with Compliance Management Gateway one-pagers & charts
• Share it with: Compliance leads, legal counsel, academic affairs, licensure coordinators, online learning leaders

A big thank you to Shari for developing this thorough handbook to support institutions in managing state authorization of distance education and for sharing the following overview today on Frontiers.

Overview of the New State-to-State Institutional Approval for Distance Education Handbook

From my experience in regulatory work, such as state authorization, I have found that practical information and guidance are the most helpful. When I started working in state authorization and higher education regulatory compliance (before SAN and SARA), I had a wonderful mentor who shared very valuable information in a concise manner. This handbook is intended to

1. encapsulate the knowledge that I have gained from working and collaborating with so many in this area, and,
2.  to provide step-by-step processes for “doing” state authorization outside of SARA.

The handbook addresses the practical aspects of seeking and applying for approval to offer educational activities and operate as an institution of higher education in another state outside of the institution’s home or domiciliary state. To be successful in this complicated area of regulatory compliance, it takes an institutional “village.”

Using the Handbook

The handbook is segmented into Part I. Foundational Elements, which covers the why part of compliance (both on the part of the regulatory agencies and the institutions), who (as in the triad), what if we don’t (consequences for noncompliance), and the distinction between program approval and state institutional approval. Part one also includes a discussion on required student location/relocation policies for institutional compliance.

Part II, the Development of Institutional Processes to Research, Analyze, Communicate, and Maintain Information, includes two sections. The first section covers institutional research, which provides a roadmap of how to start, who to involve, and how to manage the process. It also has suggestions on types of data to compile for easy access (and where to store it). The second section of Part II. covers state regulatory agency research and strategies for conducting it, recording the data, analyzing the institutional data versus the regulatory agency requirements, plus communication guidance.

Due to the density of the content, we have added graphics and text boxes to highlight critical information throughout the document. The handbook is designed to be a resource that you can print and refer to as needed or use the digital version. After the conclusion are five appendices of useful resources, including possible documentation requirements, draft templates, checklists, tips, and general state authorization resources.

As a general reminder to all institutions, in addition to having obtained authorization to provide educational services in states in which institutions are not legally domiciled, as detailed in the handbook, institutions must also be in compliance with the applicable federal rules and state requirements. These include Title IV certification via the Program Participation Agreement required under the Higher Education Act, reciprocity (where applicable), state professional licensure requirements, such as those covering program and curriculum approval to satisfy state educational requirements (where required), and other applicable general laws. Also, remember that the threshold for compliance with state authorization requirements is ONE student. SAN is a great resource for these issues.

Thank you to Cheryl and the rest of the SAN team for the opportunity to collaborate on another SAN resource!

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Alongside this new report, you’ll find a wide range of resources on the SAN website, including charts, papers, and examples of best practices, to support compliance for interstate distance education. We also encourage you to explore our professional licensure resources, as well as newer materials that address interstate employment law responsibilities and global compliance.

Looking ahead, before the close of 2025, SAN will publish more important resources:

• A fourth major SAN report, which will summarize an intensive study on how institutions are implementing professional licensure requirements.
• The third edition of State Authorization of Colleges and Universities: A Handbook for Institutions and Agencies will be available on Amazon.

For those unfamiliar with the State Authorization Network, SAN was created in 2011 as an additional membership group by WCET (the WICHE Cooperative for Educational Technologies) in response to emerging federal regulations requiring institutions to meet state authorization requirements for distance education.

SAN was designed to provide institutions with resources, training, and a collaborative community to navigate the complex landscape of state and federal compliance. SAN operates within WCET’s broader mission of advancing digital learning in higher education, focusing specifically on the regulatory and authorization challenges that impact institutions and the students they serve.

Institutions or organizations interested in joining SAN can visit the SAN Membership webpage for details or connect directly with SAN staff at san-info@wiche.edu to see how membership can support your compliance journey. SAN is here to help with your compliance needs!

This post was written by Shari Miller and Cheryl Dowd