Highlights from the National Meeting on State Authorization Reciprocity

A national meeting on next steps in state reciprocity was held in Indianapolis on April 16 and 17.  The purpose of the event was to serve as an initial introduction to representatives from each state about next steps in reciprocity.

The session focused on the report:  Advancing Access through Regulatory Reform: Findings, Principles, and Recommendations for the State Authorization Reciprocity Agreement (SARA) that was recently released by the Commission on the Regulation on Postsecondary Distance Education.   The Commission, which is a committee formed by APLU (the land-grant universities) and the State Higher Education Executive Officers, built upon the work of previous efforts of the Presidents’ Forum/Council of State Governments and the regional higher education compacts.  You can see a short history of state authorization and the reciprocity efforts on our web page.

Sponsored by Lumina Foundation, the meeting attendees included representatives from 47 states.   Delaware, Hawaii, and New York were not represented.  While they did not send participants, we know that there was interest in the first two of those states in participating. Others in attendance to this invitational event included those who had involvement in shaping the reciprocity language.

Opening Remarks and SupportHandshake

The report is meant to be a framework for reciprocity with additional provisions to be detailed in the final SARA wording.  The meeting started with several introductory sessions presenting the principles outlined in the report.

A letter was read from Molly Corbett Broad, president of the American Council on Education, lending her support to reciprocity.  Hal Plotkin of the U.S. Department of Education had the most memorable metaphor of the night, which you can ask me about later.  While the Department of Education cannot formally endorse the work, he brought a two-word message from the Secretary Arne Duncan and  Under Secretary Martha Kanter:  “thank you.”

Some Questions that Arose

If they can receive foundation support to begin the effort, the regional higher education compacts (Midwestern Higher Education Compact, New England Board of Higher Education, Southern Regional Education Board, and Western Interstate Commission for Higher Education) will be charged with jointly implementing the agreement in as seamless a way as possible.  Regional sessions were held to cover additional fine points of reciprocity and to gather comments and questions from participants.  There were many items on which there were agreement and many questions were raised.  David Longanecker, president of WICHE, highlighted a few in a final plenary session:

  • Accreditation.  There is  still some angst about the efficacy of depending on accreditation for quality assurance.  David sees reciprocity as a way to give us all more license to work with the accrediting community.  Working together, we should be able to have more evidence to take to the accrediting agencies about any concerns.
  • Fees.  The report was relatively silent on fees.  The current plan for fees includes:
    • State fees to institutions.  The state might decide to charge an institution for the process of authorizing it to participate in SARA.  States raised questions about their own ability to charge institutions (this might be currently prohibited in some states) and the reorganization of duties required.
    • Institutional fees to join SARA.  Institutions participating in SARA will be charged a yearly fee on a sliding scale based on overall institutional FTE:  $2,000 for those less than 2,500, $4,000 for those 2,501 – 10,000, and $6,000 for those more than 10,000 FTE.  Due to the current high variance in how “distance education” enrollments are counted, overall institutional FTE is the current proposed metric.
    • State fees to join SARA.  States in a regional compact will not be charged.  For those states and territories not in a compact (District of Columbia, New Jersey, New York, Pennsylvania, and Puerto Rico), they would be charged $50,000 to affiliate with a regional compact for this one purpose.  (UPDATED: 04/18/13 – Delaware is part of SREB, while Pennsylvania is not in a regional compact)
  • Legislative and Regulatory Language.  States will need assistance with the proper language.  While the regional compacts can’t lobby, they plan to provide some help in crafting language and in connecting states to learn from each other both about legislative language and  in handling the fees issue raised earlier.
  • Determination of Home State.  There are several examples of complex relationships and the details on those outliers needs to be considered.  It is clear that institutional shopping for a state will not be tolerated.
  • Professional Accreditation.  There was a proposal to have more restrictions on education offered in fields of study in which licensure or other professional accreditation is required in a state.
  • Metrics for Holding a State Accountable.  Clear metrics will need to be developed as to what a state reports.
  • The Physical Presence Limit of 25% of Course Instruction.  More justification, details, and metrics were requested.

Again, these are all questions.  Some reflect items on which this is considerable work, but either additional details, subtle nuances, or more justification is needed.  A few of the items will need much more work.

Next Steps

Recordings of the meeting will be made available in the next few weeks.  When I receive the links, I will post them to the blog.  Watch for additional follow-up information from the Presidents’ Forum and the Commission.

The regional compacts are very optimistic about receiving grant support to move forward on this work.  Once they do, they will hire staff and hold regional meetings to discuss these issues.

Finally, A Note about Tone

While much of the meeting was very positive, there was significant regulator bashing during the meeting.  Some of those with regulatory roles let me know of their displeasure.

While there are regulations that are real head-scratchers, there is real purpose behind many of these regulations. We should not paint everyone charged with overseeing authorization in the states with the same brush.  They are charged with upholding their laws.  They are charged with protecting students.

Reciprocity is asking them to make significant changes in their work, to go out on a limb and trust others, and to accept the risk of those changes.  Since they will face much of the impact, the least the rest of us can do is respect them and listen to them.


Russell Poulin
Deputy Director, Research and Anaylsis
WCET – WICHE Cooperative for Educational Technologies

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Executive Director WCET (WICHE Cooperative for Educational Technologies)

10 thoughts on “Highlights from the National Meeting on State Authorization Reciprocity

  1. I also want to thank you, Russ. We encounter the same disconcerting tone with accreditation. It is the same misperception you report, and it is not productive by any measure. Accreditors, as Patty Milner notes about state regulators, are critical partners working for the same principles of quality we espouse. It will be by working with them, not against them, that we will improve students’ learning opportunities.

  2. “They are charged with protecting students.” Right there is the absurdity of these regulations. Students can protect themselves. We are not all children that need regulators to protect us every time we wake up and go to bed. Right now, distance education is choking to death b/c people are trying to protect us. Argghhh…..just back off already!!! If 75 percent of the regulators would go away, what…..would students all get cancer or something? Mercy!

    1. So….I’m working with a student who applied for a distance program from a public institution around Thanksgiving. They accepted her in February. A month or so later they pulled her admission because the institution was not approved in her state. Now she probably won’t be able to find a program to accept her because the deadlines are all past. You may disagree with the regulation, but the institution treated her shabbily. They knew if they were approved or not and did not do right by her. She won’t get cancer, but who is going to repay her for the lost year of her life and the lost year of income she could have gained by graduating on the schedule she envisioned??

      1. I guess I blame the govt agency that made the silly regulation, not the school. I do wonder why the school accepted her in the first place….?

  3. Thank you Russ for your commitment to sharing information quickly and effectively with everyone involved in this process. It is vital that we as institutions view state regulators as partners in providing high quality educational experiences for students. As you said, it is also important to remember that regulators are charged with carrying out their states’ regulations. Those regulations serve a purpose deemed appropriate by the legislative bodies of that state. Many of the current regulations where passed more than a decade before the current spotlight was shined on state authorizations, leaving regulators struggling to keep up with a rapidly changing and expanding industry. When we take the time to understand the intent of each states legislation, seeming disparities often make more sense and are easier to address.

  4. Thank you, Russ, for your synopsis and commentary. While the process of following the state authorization regulations is time consuming and sometimes confusing, we have found the many state regulators we have emailed, written, applied to, or spoken with in person to be anything but helpful and willing to work with us. The states’ authorization regulations existed before the 2010 Federal regulations. No one ignored them on purpose; we didn’t think they applied to distance learning programs. Now that everyone knows that these regulations apply to them, we should look forward to working together on SARA for the good of our students and our institutions.

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