Anything new with state authorization or professional licensure?

One of my favorite things about working in higher education regulatory affairs is that it is Christiaan Partridgealways changing.

Just like in spring, there are new things cropping up all around us. In our field, it’s fresh ideas and issues and regulatory requirements that are always making an appearance.

I do know that that can also be a frustration, so my aim is to keep you up-to-date as best I can.

But with SARA continuing to gain momentum and publicity, and the federal government proposing new rules for distance education teacher prep programs, the field continues to be exciting.

Currently there are 36 SARA member states and over 800 participating institutions ( In spite of some in-state opposition, late last week the president of the New York Commission on Independent Colleges and Universities, the Chancellor of The City University of New York, and the Chancellor of The State University of New York jointly sent a letter to the New York Education Department strongly supporting New York joining SARA. These three entities represent all types of institutions located in New York and this broad support should go a long way to making SARA a reality for the state. Historically New York did not regulate many out-of-state institutions so there will be little difference for them.

However, for the number and size of institutions located in New York, this will have a huge impact.

It will reduce the time, effort, and cost of compliance on a state-by-state basis, which hopefully will slow down the rise in tuition rates at those institutions.

Now, adding to the already complex field of teacher and administrative prep programs, the federal government is proposing new rules for those offered through distance education.

You can read a blog about this on the WCET Blog. In a nutshell, the federal government is proposing that each state have a rating of teacher prep programs (like, low-performing or at-risk) based on several indicators. That means there could be 51 different programmatic standards (each state plus the District of Columbia).

Does this remind anyone of state authorization over the past number of years?

If a program falls short of meeting any one state’s level of acceptability (based on the indicators), it may be considered low-performing or at-risk in all states – even though it may meet the thresholds in other states.

This is a significant issue – one for which the U.S. Department of Education is seeking comments.

Your comments will be valuable. Visit:

See? There is always something new in higher education regulatory affairs! Stay tuned!


  1. Amarilis Vazquez on September 1, 2017 at 2:39 am

    Hi Sharyl,

    I found your website about a year ago because I was searching for tips and help in my new position as compliance assistance at a private university in the central Florida area. If you are ever in the state of Florida to do trainings or seminars, please let me know so that I can try to convince my supervisor so send me to the seminar. Recently I attended the FLVC Symposium on SARA held in St. Petersburg, Florida. It was very informative and I got my picture taken with Marshall Hill. I have hopes that soon Florida will become a SARA state as well. However, in my case, it won’t make my workload that much easier because the way our school operates sometimes creates physical presence in some states so, as you know, applications can be quite extensive and time-consuming.

    Don’t you find that sometimes state regulations are a bit outmoded in the face of present day reality? For example, how do reviewers when auditing an extension site go through 500 files of online teachers to make sure their qualifications meet state standards? I recently talked with a state reviewer who did not want to do that. Then there are states that require every teacher to fill out an instructor qualification form even if they only teach one course one semester and don’t return to the college anymore.

    • Sharyl Thompson on September 1, 2017 at 3:32 pm

      Thank you, Amarillis, for contacting me.

      Fortunately, Florida has applied and been accepted into SARA with an effective date in early October. That is great news for all Florida degree-granting, accredited institutions. Massachusetts and California are the two states yet to join.

      Your comment about physical presence intrigued me. If you’re saying your institution has physical locations in other states, then yes, you will still need authorization in those states outside of SARA. Once you are accepted to participate in SARA, you ma conduct a number of activities in other SARA states without seeking additional authorization. So, it depends on how you define “sometimes creates physical presence” as to whether or not you will need to apply for authorization.

      There is no question that state regulations are often out-of-date for our current higher education reality. There are a number of reasons for that, although it is MUCH better now than it was when I first started doing state authorization work back in 2001. You would be surprised as to how closely states review their individual state authorization applications. At a site visit, they likely would not go through every faculty file (like 500); instead they would review a random sampling. States have discrepancy as to how and what they review. The states’ role is consumer protection and they are required to make sure institutions are meeting their standards to avoid any appearance of fraud. Qualified instructors is only one part of that, as you know.

      Thanks again for your comments and questions. I appreciate it – and if your institution ever needs any assistance in navigating state authorization matters (including site visits), please feel free to reach out to me.

      Have a great weekend.

      Sharyl Thompson
      Higher Education Regulatory (HER) Consulting

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