Updated 02.07.17
Information on new Statewide Authorization Federal Regulations - Effective July 2018
(Thank you to Russ Poulin, WCET and Jennifer Shanika, NC-SARA)

Updated 03.30.15
Final 2015 Summary of SAN/SARA Information

As Chemeketa's State Authorization Network membership ends March 2015, I thought I'd share out a summary of some of the best places to get information now and into the future.

  • Russ Poulin's blog is a good place to go for updates on federal regulations and other related topics. Federal regulations will probably heat up again in July 2015.

Updated 01.27.15
Here is a document with definitions for State Authorization terms that may be useful to you.

Here is a draft list of WCET/SAN FAQs that may also be helpful to you. I will post the finalized version when I have it.

For those interested in information about Professional Licensure and State Authorization requirements, below is a link to a webinar from 01.13.15, with related slides and the Chat Log. I've also added a Talking Points document for quick reference:

For those interested in information about the importance of making sure that information we submit to the public is accurate, below are notes about Misrepresentation:

Updated 12/30/14
Go to the link below for a good 2 1/4 page summary on the Distance Education state and federal regulations and where to find updated information:
State and Federal Regulations on ‘State Authorization’ of Distance Education

Updated 12.08.14

Contact for SARA Application Questions
(HECC accepting applications beginning 12.01.14)

Alethia Miller, MPPAcademic Program Evaluator | __Office of Degree Authorization__
Oregon Higher Education Coordinating Commission (HECC)
503-373-0003 | alethia.miller@state.or.us+
775 Court St. NE / Salem OR / 97301

Updated 11/13/14
Oregon is now a member of SARA!
See Announcement
This means that all 17 community colleges can now apply to become member institutions of SARA
(See Application Instructions and Documents under the 10/21/14 Update below)

Updated 10/31/14

OCCDLA Fall 2014 SARA Presentation Document

Updated 10/28/14

HECC meeting schedule

Updated 10/26/14

State Authorization Sample Inquiry Letters

Updated 10/21/14 and 12.08.14

SARA Institutional Application Instructions and Documents
SARA Institutional Application Process Website (Updated 12.08.14)

Updated 10/17/14
A comprehensive review of SARA Agreements, Policies and Standards for states and institutions.
There are 8 sections:
  1. Definitions
  2. States and Membership
  3. Institutions and Participation
  4. Consumer Participation
  5. Physical Presence Standards
  6. Data Submission Requirements for Institutions Participating in SARA
  7. Complaint Resolution Reporting for States Participating in SARA
  8. Revisions to Policies and Standards

Updated 9/23/14
Webinars and Slides

State Authorization for Military Students: Navigating the Defense MOU and State Laws - 8.20.14
Webcast Slides
YouTube Webcast Recording - 59:14
Chat Log

Series of Two Webcasts Offered in Partnership by M-SARA, OLC, UPCEA, and WCET

State Authorization for Distance Education: The Future for RECIPROCITY - 8.19.14
Webcast Slides
YouTube Webcast Recording
Webcast Q & A

State Authorization for Distance Education: The Future for REGULATIONS - 8.14.14
Webcast Slides
YouTube Webcast Recording
Chat Log

Updated 7/29/14

OCCDLA Summer 2014 Meeting State Authorization Notes

Updated 6/16/14

Russ Poulin's Blog clarifies our most current status regarding federal regulations

SHEEO State Authorization Survey Results now available in searchable web format

  • WICHE -SHEEO has been working hard to make it as easy as possible for us to find the information we need to be compliant with State Authorization. They have created a web-based searchable version of the survey so you can find the most up-to-date information for all the states who responded to the survey. When you click on a state you will be in the View Tab. For a complete list of revisions dating back to about May 1st, simply click on the Revisions Tab.

Important DOE Proposed Changes to State Authorization Regulations Currently Being Discussed That Will Affect All of Postsecondary Distance Education

  • See Phil Hill's Blog Post
  • See Russ Poulin's Blog Post
    • (Russ is the Deputy Director for Research and Analysis, WICHE's Cooperative for Educational Technologies)

Alba Scholz, SAN Coordinator, PowerPoint Presentation, Fall Meeting, 2013

"The State of State Authorization: An Update for Higher Education Leaders"

SARA (State Authorization Reciprocity Agreement) State Membership Checklist:

Provided by Alba Scholz, SAN Coordinator

Important SAN/SARA Websites

Excellent Contact for HECC-related questions:

Alethia Miller, MPPAcademic Program Evaluator | __Office of Degree Authorization__Oregon Higher Education Coordinating Commission (HECC)503-373-0003 | alethia.miller@state.or.us+775 Court St. NE / Salem OR / 97301

SAN General Information

SAN Sample Inquiry Letters

Included below are the meeting notes and two presentations that were shared at the SAN meeting.

Update via email September 28, 2012
Please see the email below from Marianne Boeke at NCHEMS re: state authorization updates from SHEEO.
Pay special attention to paragraph 2 in the Complaint Process section. We can now link directly to their list without having to maintain our own copy of their list.

Greetings from Boulder!
I am pleased to announce that the online listing of complaint process and fee summary reports are now available on the SHEEO web site. These reports have been updated as of September 2012 based on information provided on the June 2012 SHEEO surveys on state authorization. WCET’s (WICHE Cooperative for Educational Technologies) State Authorization Network supported this work.

SHEEO State Authorization Main Web Page:

Complaint Process Report
The Complaint Process Report is a compilation of all the complaint process web links and/or explanation of the process for the 68 agencies within the US (including Puerto Rico and Washington, DC). This list is intended for students who may have a complaint against a higher education entity.

According to the latest information from the USDOE regarding state authorization and the complaint process list; institutions may now post a link from their web site directly to the SHEEO complaint process report web site for the purpose of listing the complaint process for each of the agencies responsible for state authorization. Here is the direct link to the Complaint Process Report:

Fee Summary Report
The Fee Summary Report is a compilation of each state agency authorization fee structure and possible exemptions for the 68 agencies within the US (including Puerto Rico and Washington, DC). This list is meant to be a guide only. For exact costs (and possible associated fees for authorization) please see each agencies web site. Here is the direct link to the Fee Summary Report:


Marianne Boeke, Ph.D.
Research Associate
National Center for Higher Education Management Systems (NCHEMS)
3035 Center Green Drive, Suite #150
Boulder, CO 80301
303-497-0357 (phone)
303-497-0338 (fax)

Update by email September 11, 2012
You may have already seen this email. It's an update on the State Authorization issue. The US DOE's regulation was struck down by the US District Court in July 2011. The department appealed and the US district district court's decision was upheld in June 2012.Have said that though, the email below explains that the Court remanded the ruling back to the Department. There is no word yet on what that means but I wanted you to see the email.

I'm attending the SAN coordinator's meeting in October.
Again, this does not change the need to comply with state requirements.
---------- Forwarded message ----------
From: Russell Poulin <RPoulin@wiche.edu>
Date: Thu, Aug 16, 2012 at 3:41 PM
Subject: USDOE Remand Letter
To: WCETSANCOORD@wcet.wiche.edu

Hello WCET members –

On today’s phone call, we heard from Sophia McArdle of the U.S. Department of Education that she really could not provide us with any clarifications on the Department’s take on state authorization because the Court’s had remanded the ruling back to the Department. Sophia sent us the remand statement. It really does not say much except reporting back what they already knew…600.9(c) was vacated and the appeals process upheld that ruling.

She said that the Department:
  • Will review the remand order.
  • Determine what it means.
  • Develop options for next steps.
  • Choose which option(s) it will pursue.
She could not guess at a timeline.

On both the federal and state regulations, please continue to share what you learn.


Update 5/15/12

There are currently efforts to develop models of reciprocity to help states and institutions manage the State Authorization issue. A ruling is expected in summer 2012 on the U.S. DOE's appeal on the distance education portion of the federal regulations. However, states still, and have previously had, their own requirements.

SAN membership
CCWD in agreement with Bruce Kauss and consultation with Loraine Schmitt agreed to renew the State Authorization Membership for Oregon Community Colleges for April 2012-May 2013. Portland Community College has an IGA with CCWD to facilitate the membership. Two coordinators are assigned. Loraine Schmitt and Karen Smith (OCCA) are the coordinators. Their roles continue from this past year in serving as information liaisons with statewide groups. However, each institution is responsible for their own compliance on all issues.

Useful Web Resources
SARA- draft reciprocity agreement

State Higher Education Executive Officers Resources

Complaint Process Sample (also see WCET Update provided in December 8th update below)
The message below was sent to the OCCDLA list on April 20, 2012 from Loraine Schmitt

I wanted to share with you the page we posted regarding out-of-state student complaints, per the state authorization issue. We are all required to have a web page for students to let them know where they can access complaint procedures. We also cannot link to the SHEEO web page with the list of state contacts. We are required to have the pages on our own site.

I hope this helps in your efforts.

The main link to the page is located here:

The content is actually located on this page.

December 8, 2011

WCET provided this link to very helpful information with the following types of sample text/links:

Letters of inquiry to states regarding authorization requirements
Sample wording for schools not accepting students from specific states or any other states
Sample wording for the complaint process


As of July 1, 2011 institutions were to have the complaint process statements on their web sites.

Update 8/15/11
The link below will take you to a blog post outlining the complaint elements of the federal regulation. While we are waiting to learn more about the state authorization requirement, the complaint process was not part of the court ruling you may have heard about. The key message here is, we need to be adding this information to our college web sites.

The table is useful and the link to OSU is very helpful. As the notes explain, most schools are not currently in compliance and need to be working on it.

Our colleagues at Oregon State have been leaders in addressing the regulations. To see the information they have posted, go to

Update 6/9/11

We had some good discussion at our spring term meeting. I shared that Karen Smith of OCCA, will be helping to research where we might seek exemption or approval as a state. This work will begin sometime in June. CCWD will also gather collective data on out-of-state enrollments for online at all 17 colleges. At the spring meeting we agreed that we should ask CCWD to prioritize looking at California, Washington, and Idaho first. That request has been made.

Also, Megan Raymond recently updated the blog with a post describing updates she found when perusing web sites for the various state authorization procedures.


Update 5/5/11

You may have recently read that the State Higher Education Executive Officers (SHEOO) recently announced they plan to create a directory of state regulators and a compendium of state laws and regulations. They have contracted with the National Center for Higher Education Management Systems (NCHEMS) to support their efforts. Please see all the details on Russ Poulin's blog post.

There are also efforts underway to develop reciprocal agreements as part of the solution. See the guest blog post by Paul Shiffman explaining the efforts underway and who is involved.

We recently visited with Cam Preus-Braly and Krissa Caldwell about requesting OCCURS data for out-of-state online students enrolled at all Oregon Community Colleges; researching and pursuing system approvals or exemptions from states where it is appropriate; and connecting with our colleagues at the OUS offices. We will share any news we hear and look forward to an update from them at our spring meeting next week.

Update 4/21/11

Yesterday the Department of Education issued another Dear Colleague letter. It is attached. The letter outlines the most recent clarification on the Program Integrity regulations regarding Distance Education. While this allows us more time to comply, it does not lessen the need to meet requirements in other states where we have online students enrolled. The SAN coordinators have an audioconference next week to continue to discuss next steps in light of this news.

Update 4/18/2011

Last week an email was sent to the OCCDLA list including information for colleges to sign up for the listserv. It also included notes on how you might want to proceed to address the issue. Contact Loraine if you need this information.

Additionally, a message was sent today, asking folks to complete a google form so the information can be sent to WCET and members don't have to subscribe. The document is not reposted here due to privacy concerns.

The attached file may be used and distributed with proper attribution.

Update 3/31/11

Loraine met with Sona Andrews, Vice Chancellor for Academic Strategies at OUS, last week. She is the representative for the State Authorization Network for OUS. They have done quite a bit of work.

OSU is posting some information to a web site they hope to update weekly.


To date, here is a summary of the OUS activities:

  • Established institutional representatives from each University to work on the issue
  • Established a work group with bi-weekly audio meetingsto move ahead and stay on top of things (These do not resume until after the Boulder meeting on the 6th and 7th)
  • Compiled a list of the numbers and states where each university has students participating in DE from other states
  • Created a summary spreadsheet of the states requirements- Contact Loraine for this file. It was attached in the OCCDLA update from March 31.
  • Estimated the cost of applying to every state where they have students
  • Met with Rep. Wu in Portland - David Wu Letter.pdf
  • Wrote a couple of letters to some states requesting approval on behalf of the system
  • OSU plays a major role because of their strong support for DE

Last week there was a letter sent to the US DOE from 17 senators requesting the regulation be rescinded.
State Authorization Senate Letter 03-23-11.pdf
Previously, there was also a letter sent by ACE to Arne Duncan also requesting a rescission
State Authorization ACE Letter 3-2-11.pdf

Membership Update 3/23/11

Network Members

We are still waiting for a few more to confirm one way or another, but here is the current list of those who have committed to joining the State Authorization Network:

  • Chemeketa Community College/Oregon Community Colleges
  • Colorado Community Colleges OnlineConnecticut Distance Learning Consortium
  • Idaho Office of the State Board of Education/ Idaho State Univ.
  • Minnesota Learning Commons
  • North Dakota University System
  • Ohio Learning Network
  • Oregon University System
  • South Dakota University System
  • University of Michigan partnership
  • University of Wyoming
  • University of Maine System
  • Washington State Board of Community and Technical Colleges
  • Institutions
  • American Academy McAllister Institute
  • Cochise College
  • Harrison College
  • Penn State Outreach
  • University of Alaska Fairbanks


This page is being used to provide updates and information regarding the US DOE's regulation about state authorization. We are currently members of the WCET State Authorization Network (SAN). I will attend the meeting in Boulder on April 6 & 7.
As members of this network, your colleges receive updates from Network activities and will also be invited to participate in web casts or other activities. These are benefits of the membership and are not open to the public.
Email to OCCDLA from 3/22/11
This is a copy of the email I sent to the list. It is regarding the topic of the U.S. Department of Education’s regulation requiring that institutions of higher education be authorized to operate out-of-state in each state. The requirements do apply to distance education where an institution may be offering online degrees or even online classes to students living in another state. This regulation means, you must comply with the requirements in the student’s home state or risk losing federal financial aid. The regulation was announced in October 2010 and goes into effect on July 1, 2011. There is currently no extension for distance education.
Hopefully this is not the first you’ve heard of this issue. Chemeketa, on behalf of the Oregon Community Colleges, via the state operations agreement with CCWD joined the State Authorization Network. This entitles your colleges to bi-monthly webcast updates for all members, ongoing networking opportunities via e-mail, web and phone. I will attend the meeting and training in Boulder, CO on April 6 and 7. I’ll send out updates to the list as things develop. Information about the state authorization network is at

For some background information please see the following links.

  • WCET website with Russ Poulin’s blog with rich resources and posts around the issue. You may want to see old blog posts to catch up if needed.


  • Dear Colleague Letter from the United States Department of Education answering common questions about the regulation


  • A list of things you can be doing as we learn more about how to proceed. I would suggest starting with the first 7. I started by contacting legal counsel, institutional effectiveness, financial aid, chief academic officer, and executive deans. We are going to examine the enrollment history of out-of-state students taking online classes over the last year. So far we’ve learned we have the most students in Washington, California, and Texas. Further investigation is obviously necessary.


A starter list of requirements state-by-state http://wcet.wiche.edu/advance/starter-list

I'll send out updates as I hear news, but be sure to track this. It’s very complex and the impact of it means something unique to each institution. I will be meeting with Krissa Caldwell of CCWD and Karen Smith from OCCA in a couple of weeks. I have also made contact with the OUS representative to the state authorization network.