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Evolving State Authorization of Online Programs: A Call to Action

The EvoLLLution | Evolving State Authorization of Online Programs: A Call to Action
In order to maintain the early success of SARA, and to continue the work of simplifying and unifying authorization to expand access to distance learning, it’s critical to ensure the system remains manageable, and for institutions to become increasingly involved in the organization.
For educators working in online and distance education, an understanding of state authorization often means a vague familiarity with the issue, and confidence that it is a non-issue. This is thanks to the nearly nation-wide adoption of the State Authorization Reciprocity Agreement, more commonly known as SARA—a young but comprehensive solution to what can be a thorny and complex issue. We contend, however, that a passive understanding of state authorization is not sufficient at this moment within a long-term evolution of process and policy. Instead, an active stance, including collective attention and work toward this evolution, is our call to action.

So what exactly is SARA? The State Authorization Reciprocity Agreement is a voluntary agreement, or contract, between states. It provides a uniform set of standards and processes to ensure consumer protection for a state’s residents enrolled in distance education programs at out-of-state institutions. SARA is administered by four regional compacts. In essence, SARA is the delegation of a state’s “police power” to a quasi-governmental agency. Institutions can voluntarily join SARA and be bound by its standards in lieu of subjecting themselves to direct state oversight by each of the 50 states and U.S. territories. SARA was adopted only a few years ago, and not until summer 2018 did all states finally join (with the notable exception of California).

The benefits of state reciprocity are well understood and appreciated: It alleviates the daunting, burdensome requirements of each state, resulting in greater efficiency and lower costs for institutions, greater access for students, and less complexity and uncertainty for all. But SARA is a relatively new solution, and as technology and education continue to change and evolve, so will this particular governing framework. While it’s true that SARA is an improvement over the old approach, that remains true only if it continues to provide an oversight function that’s more efficient than what the states can provide on their own. And this efficiency must extend to institutions—arguably the most impacted group of stakeholders.

Because it is still in its infancy as a (nearly) fully adopted and implemented framework, SARA lacks a well-defined process for ensuring appropriate transparency and engagement. In fact, SARA’s process to ensure sufficient transparency and input is contained in a single, vague provision of the unified agreement: “Procedures to solicit and consider suggested amendments shall be developed, published and administered by NC-SARA, in concert with the regional compacts.” This is unlike governmental rule making, which has clearly established and detailed procedures for informing and engaging citizens, which are protected rights in our democratic legal system. While this may not be of concern to many institutions of higher education (IHEs), if SARA evolves without the necessary transparency or input from its most impacted constituent group, it could lose its value for IHEs. This is precisely why we call for institutions to maintain vigilance and engagement with SARA: to ensure their voices and perspectives inform the inevitable evolution of the framework as standards and policies are revised, clarified and updated in response to changes in the environment. IHEs should make an effort to shape SARA to ensure it can best meet its stated purpose.

A return to the overwhelming burden of life before SARA isn’t an option most want to entertain. Before SARA, each institution was saddled with an impressive amount of compliance work, and SARA makes that particular burden much lighter for most. For that reason, we don’t advocate going back to a pre-SARA state.

However, we have noticed that clarifications and changes in SARA policy, as well as the regional compacts’ interpretation of those policies, lacks consistent notice and opportunity for input. Additionally, some SARA compliance requirements—for example, those for reporting the physical location of students—are more stringent than those of any state or of the federal Department of Education, thereby diminishing one of the core and essential benefits of SARA: eliminating the overly burdensome requirements of compliance for institutions. This core benefit must be preserved, or the value of SARA may be diminished to the extent that it loses its relevance. And because SARA lacks the framework to guarantee institutions a seat at the table in future policy decisions, institutions must take it upon themselves to be a part of the conversation.

We recommend substantial, prolonged input from institutions to ensure that SARA compliance requirements do not begin to outweigh its efficiency benefits. We recognize that the implementation of SARA was the impressive result of persistent, concerted effort. The continued success of SARA will require the same effort. For SARA to remain a viable solution for all stakeholders to the problem of 50-state regulation, institutions cannot become complacent. They must sustain the momentum through continued collaboration with other institutions, NC-SARA, and their regional compact.

The value proposition for a national framework exists now, and we propose to ensure SARA’s value by engaging in the following joint work:

  • Reducing the ambiguity of SARA processes by defining, perhaps even enlarging, its scope;
  • Ensuring transparency and broad stakeholder input for any new policy or process, especially those impacting institutions;
  • Developing shared, low-cost resources and expertise to assist institutions in navigating entry into and maintaining an informed membership of SARA;
  • Urging states and institutions to define their roles and fund the work needed to remain in compliance.

The benefits of a national framework are obvious: Institutions and states must follow only one set of rules instead of over 50. We look forward to joining our colleagues in informing the evolution of this national framework so that it is flexible and responsive for the long term, and provides sufficient support and value for institutional participation.

Join the conversation and get engaged; the following resources are a good place to start:,,

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