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CCME Grapevine 2015 May

MAE 2015 Volume: 10 Issue: 5 (June)

State Authorization and Reciprocity by Lane Huber

At the 2015 Council of College and Military Educators Professional Development Symposium, a roundtable was conducted focusing on state authorization issues and reciprocity. Dr. Marshall Hill, Executive Director of the National Council for State Authorization Reciprocity Agreements (NC-SARA) led discussions on the history of state authorization, the development of the State Authorization Reciprocity Agreement (SARA) and how states and institutions may join the network.


In the October 2010, the Department of Education issued a series of regulations including one specifically relating to "State Authorization." The guidance in § 600.9(c) stated that any institution of higher education must secure authorization from each state in which students reside. While this § 600.9(c) was vacated by a federal court in 2011 (a decision that was upheld in an appeals court in 2012), individual states still require institutions to follow their state regulations.

More importantly for those of us involved with voluntary education, the Department of Defense Instruction (DoDI) 1322.25 includes an appendix containing the DoD Voluntary Education Partnership Memorandum of Understanding (MOU) between DoD Office of the Under Secretary of Defense for Personnel and Readiness (USD (P&R)) and educational institutions. This MOU specifically states that educational institutions must comply with state authorization requirements consistent with regulations issued by ED, including 34 C.F.R. 600.9 and must meet all State laws as they relate to distance education as required.

In other words, even though the federal regulation by the Department of Education was vacated, institutions that have signed the DoD MOU are required to follow State laws related to the delivery of higher education.

The complexity of state policies and regulations has proven to be extremely difficult, not to mention expensive, for individual institutions. This is especially true for smaller schools with limited compliance staff. Reciprocity agreements between states quickly became the most promising way to ease this burden.


According to the NC-SARA web site, "The State Authorization Reciprocity Agreement is an agreement among member states, districts and territories that establishes comparable national standards for interstate offering of postsecondary distance education courses and programs. It is intended to make it easier for students to take online courses offered by postsecondary institutions based in another state. SARA is overseen by a National Council and administered by four regional education compacts."

During his presentation, Dr. Hill explained that SARA follows the "driver's license" model. Gain approval in your own state and the other member states will recognize that approval.

States apply through the four regional compacts (Midwestern Higher Education Compact, New England Board of Higher Education, Western Interstate Commission for Higher Education, Southern Regional Education Board). The three states that do not belong to a regional compact (NY, NJ and PA) are provided other options of joining SARA. Once states are approved through the regional compact and the NC-SARA National Council Board they are invited to begin enrolling individual institutions within their own state. The institutions must adhere to a common set of standards to be eligible, and to remain eligible, for membership in SARA.

At time of publishing there are 23 member states:
Alaska, Arizona, Colorado, Idaho, Indiana, Kansas, Louisiana, Minnesota, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Dakota, Ohio, Oregon, South Dakota, Vermont, Virginia, Washington, West Virginia, and Wyoming.

Currently there are additional states in various stages of application for membership. For updated status of legislation and application status of individual states, or for more information on NC-SARA, visit their website at

Jeff Cropsey Note from Jeffrey Cropsey, CCME President: CCME thanks Lane Huber,
Bismarck State College, Chief Distance Learning & Military Affairs Officer,
for his synopsis of the CCME Roundtable on State Authorization Reciprocity.
For more information about our organization, please visit