SARA (State Authorization Reciprocity Agreement)

From birth to its current state: My experience with SARA (State Authorization Reciprocity Agreement)


I started doing state authorization work for Capella University in 2001.

I was hired for a different position in late 2000, but the same day I started so did Capella’s first director of corporate sales whose job was to hire recruiters across the United States to bring new students to the University. This recruiting activity swung the door open wide, making us aware how highly regulated institutions were and I began to learn what it would take for Capella to be in compliance with each state’s regulations.

Also in about 2002 I attended my first National Association of State Administrators and Supervisors of Private Schools (NASASPS) annual conference. There I had the opportunity to meet a number of state regulators face-to-face after having only met them by phone or postal mail previously. It was during the sessions at that conference that I determined if the opportunity arose I would do everything I could to try to make state authorization more efficient and less expensive for institutions.

One of my first efforts in this direction was to give conference presentations and eventually lead a task force through NASASPS to design common application forms to be used by numerous states. To date, many states asked for the same information but required that it be put into a state-specific form. Having common forms would not require changes in regulation but would make it possible for institutions to create the information once and have it accepted in the same format as other states. Good progress was being made but then the task force was disbanded.

In 2004 a collaboration of accredited, national, adult-serving institutions joined together to form the Presidents’ Forum hosted by Excelsior College in Albany, NY. Its mission was to advance the recognition of innovative practice and excellence in online learning. ( Each year the Presidents’ Forum chooses an project to benefit higher education.

With support from the Lumina Foundation and in collaboration with the Council on State Governments, the Presidents’ Forum formed a team of higher education professionals in 2009 to develop a strategy to propose a more efficient and less expensive means for institutions to obtain the numerous state authorizations necessary to conduct activities across state lines. This team’s objective was to draft model legislation that could be adopted by states allowing them to recognize the authorization from other states, thus reducing the number of states an institution needed to apply to for individual state authorizations.

I was invited to be a member of this Drafting Team. Over the next eighteen months, our team met to draft this model legislation. As the sole institutional regulatory compliance member of the team, it was wonderful to begin to see the fulfillment of a vision I had had since my early days of doing state authorization work. Our meetings were intense, lively, and each member worked very hard to reach the goal of simplifying state authorization across state lines. Often we would talk about what success would look like – 5 states participating? 10 states? In 5 years; in 10 years? We brought many voices to the table in order to hear everyone’s concerns and ideas. This included state regulators, accreditors, higher education associations, institutional representatives from all sectors, etc. As one can imagine, there were almost as many ideas and concerns as there were people who attended the various meetings.

As we progressed in the process, even Drafting Team members realized this task would be more complicated than first expected. Many people would tell team members that this should be easy and it did not need to be complicated. But the further we got down the road, the complexities became more evident to many more people. What would we call this new process? What should be the criteria for participation? Who should oversee it? What kinds of institutions should the agreement apply to? How detailed should the draft be? What would happen in this situation; in that situation? What should the triggers for authorization be? How could we propose something that would gain wide acceptance from states and institutions? How do we weigh the various interests and concerns of the stakeholders?

Later into the process, leaders from the four regional compacts offered to be the overseers of what now is called the State Authorization Reciprocity Agreement (SARA). Although the regional compacts had no experience with state authorization they did have experience with creating and managing compact agreements between and among the states and had long-standing relationships with state legislators, which would be a key to the success of the agreement. With the involvement of the four regional compacts, the model legislation the Drafting Team had created was modified significantly but without removing the most important factors. The states would be members of the agreement and institutions located in those states could apply to participate in the agreement. It would be available to all accredited, degree-granting institutions.

Again, the Drafting Team thought if ten states signed on the agreement in the first year that would be significant. However, I’m happy to report that at the time of this writing and after just 2 years of existence, 29 states have agreed to become members of SARA! Twenty-nine!! Over half of the states will recognize and accept the authorization of institutions in the other member states. That means institutions will not need to apply to all 29 of those states for authorization but need only to apply to their home state. If accepted, they can then “operate” in the other 28 states without needing to apply there individually. This is tremendous progress and I am thrilled to have been in on the ground floor of what is now a national initiative. I have often sat back and smiled to myself as I’ve seen more and more states sign on to the agreement.

It makes me wonder what is next . . . . .?!


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