Key Considerations

Every state has statutory regulations for out-of-state institutions offering online education to its residents. Many states require programs to be authorized before offering courses and/or operating in their state. "Operating" may include solicitation, advertising and/or recruiting students, as well as requiring students to complete clinical, internships and/or field placement courses.

State Authorization Reciprocity Agreement

The University of Cincinnati has been approved by the Ohio Department of Higher Education to participate in the National Council for State Authorization Reciprocity Agreements (NC-SARA) initiative. This voluntary agreement among member states and institutions establishes standards for interstate offering of distance education across state lines, shifting principle oversight responsibilities from the state in which the distance learning is being received to the “home state” of the institution offering the instructions. The NC-SARA Manual details policies and guidelines for operating under SARA.

Participation in SARA provides reciprocity to offer online/distance learning programs to residents of other SARA member states (click here for the list of current SARA states), including the following activities:

  • Limited interstate field experiences (such as clinical, student teach, internships)
  • Interstate advertising to students (print, billboard, direct mail, internet, radio, t.v., etc.)

SARA does not cover physical locations.  The following activities are outside the scope of SARA and may require state authorization:

  • Establishing a physical location for students to receive instruction
  • Requiring students to physically meet in a location for instructional purposes
  • Establishing an administrative office or physical site operated by or on behalf of the institution in the state;
  • Providing office space to instructional or non-instructional staff
  • Maintaining a mailing address or phone exchange in the state

SARA has no effect on state professional licensing requirements. SARA does not provide a means for approval with professional licensing boards for programs leading to state licensure or national certification. Therefore, colleges/programs need to continue to monitor/comply with individual state professional licensure board requirements and/or seek approval in states in which they intend to enroll students. As a SARA member any courses or programs potentially leading to professional licensure must notify all students, in writing, as to whether such offerings actually meet state licensure requirements where the student resides. If the college/program cannot determine through its contact with relevant licensing entities whether the program meets licensure requirements in the student’s state of residence, the college may meet this SARA requirement by informing the student in writing and providing the contact information for the appropriate state licensing board/s in order for the student to make that determination.

Not every state is a member of SARA. 

For New DL Programs:

  1. Know where your target students reside and, if State Authorization is required in that state.
  2. Understand which activities trigger physical presence.
  3. Review your program marketing campaign and field experience requirements.
  4. Contact Melody Clark, for additional information regarding State Authorization. 
  5. Submit the new program to the Academic Committee.

Professional Licensure-Track Programs:

  • Determine whether program meets or does not meet educational requirements for licensure/certification standards in states in which you intend to enroll students.
  • Develop program website disclosure/s regarding whether or not the program meets licensure requirements in other states.
  • Develop communications/methods to notify individual students accordingly.

Common Physical Presence Triggers:

  • Mailing Address, Telephone Number or Facility within another state
  • Field Experience (Clinical, Practicum, Internship)
  • Local Advertising (Billboards, Newspapers, Local TV/Radio)
  • Advertising or Soliciting a specific Geographic Target
  • Employing Faculty in another State
  • Articulation Agreements with other Institutions