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University of Wisconsin Madison
Projects & Initiatives

State Authorization Reciprocity Agreement (SARA)

APLU played a leading role in the creation of the State Authorization Reciprocity Agreement (SARA) system, which significantly streamlined regulations and allows universities and colleges to more easily offer online courses across the country.

While distance education grew significantly, state and federal laws and policies did not keep up.  SARA helps free higher education institutions from the maze of costly, inefficient, and inconsistent regulations and laws in different states that often make it difficult to offer online courses to students who reside outside an institution’s home state. 

On January 19, 2017 the U.S. Department of Education formally confirmed that SARA complies with the recently published state authorization for distance education regulations.

Currently, 47 states are participating in SARA, which is an interstate reciprocity system with a single set of baseline standards and procedures that institutions in participating states must meet for their distance education programs. The reciprocity system ensures institutions can easily operate distance education programs in multiple states as long as they meet the regulatory requirements of their home state. The home state regulation includes standards dealing with institutional quality, consumer protection, and institutional financial responsibility. 

How SARA Works

  • The home state of an institution is responsible for regulating and overseeing that institution’s work nationwide.  Each state ensures that its institutions meet a set of agreed upon national baseline standards, but could require additional oversight and regulation of its schools as it sees fit. 
  • Other states in which the institution in question offers distance education programs cannot regulate that institution unless the institution has a “physical presence” in the state. 
  • Institutions with a physical presence in another state, however, would be subject to regulations of that other state, but only for work done within that state. 

APLU President Peter McPherson served as vice chair of the board of the National Council for SARA (NC-SARA), and Paul Lingenfelter, former president of the State Higher Education Executive Officers (SHEEO), served as chair of the board for NC-SARA played central roles in the development of the Commission on the Regulation of Postsecondary Distance Education, which provided the framework for the reciprocity system in place today.  The Commission, which was led by former U.S. Secretary of Education Richard Riley, brought together a diverse set of higher education and state leaders, accreditors, and regulators to tackle the challenge institutions face in complying with maze of state laws and regulations.

State agencies generally require institutions to pay a fee for authorization. The fee structures vary greatly by state -- from $0 to more than $10,000 -- and may increase if the institution offers multiple programs or degree types.  Additional fees include site visits, surety bonds, and renewal fees. Cost estimates for institutions to achieve full compliance range from $76,100 for a public community college to comply with requirements in five states for 257 students to $5.5 million for a public university system to comply with 49 states. These estimates do not include the additional expense of staff time, which may cost some institutions as much as $195,000.  State authorization procedures often duplicate those of accrediting agencies, creating unnecessary and redundant costs for institutions.  For those states where an institution has very few students, the cost of compliance may exceed tuition revenue.