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The Presidents' Forum, working with the Council of State Governments and with support from the Lumina Foundation, has developed a draft State Authorization Reciprocity Agreement (SARA) that would allow states to enter into reciprocal agreements and create a template to align home state's distance education requirements.

Your feedback is requested on the document, which explains how institutions would be able to provide distance education to students in all agreeing states without having to go through the expensive process of receiving authorization in each state-an original provision of the program integrity regulations developed by the Department of Education (ED).

The draft proposes a fee structure in which institutions would pay a SARA Policy Board to manage state and institutional participation. The Presidents' Forum estimates this fee would be significantly lower than the cost associated with receiving authorization in all 54 states and territories.

In July 2011, the United States District Court for the District of Columbia threw out the state authorization provision, saying that ED did not provide sufficient notice and an opportunity for comment. Many believe ED still wants to re-introduce the provision and that states will make compulsory their rules even without the federal rule in place.

The agreement "shifts principal oversight responsibilities from the state in which the ‘distance learning' is being offered to the ‘home state' of the institution offering the instruction," say its authors. Note that SARA does not include programs leading to professional licensure-such as nursing, education, or psychology-where a state board or authorizing agency issues the license.

Send your comments to the Council of State Governments, as indicated in the draft.


Bryan Dickson

Director, Student Financial Services and Educational Programs


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