The State Authorization Reciprocity Agreement (SARA) aims to streamline regulatory oversight of online learning by allowing institutions authorized in one member state to operate in all member states without additional requirements. This initiative reduces regulatory compliance costs for institutions and increases online options for consumers while providing minimum consumer protections. Stakeholders discussed the benefits and concerns of SARA, including proposed legislative actions in Massachusetts.

1. State Authorization
Reciprocity Agreement (SARA)
Board of Higher Education Meeting | June 14, 2016

2. State Authorization Reciprocity Agreement (SARA)
 What is SARA?
 Benefits & Concerns
 Stakeholder Comments
 Gabrielle Viator, Assistant Attorney General & Senior Policy
Advisor Office of Attorney General Maura Healey
 Margaret Mattes, Policy Associate,The Century Foundation
 Michael Alexander, President of Lasell College (rep. AICUM)
 John Cunningham, CEO of UMass Online;Vice President of
Academic Affairs, University of Massachusetts
 Questions
Presentation Overview

3. State Authorization Reciprocity Agreement (SARA)
 2006 – Congress Eliminates 50 Percent Rule
 Led to proliferation of online learning, particularly in
for-profit sector
 2010 – USDOE Creates State Authorization Rule
 Required distance education providers seekingTitle IV
funding to be “authorized” in each state from which
students are enrolled
 Still awaiting USDOE regulations defining what will satisfy
requirement of “state authorization”
 Currently, each state regulates online learning
independently; requirements and fees vary by state
Origins

4. State Authorization Reciprocity Agreement (SARA)
 SARA is an effort, in part, to get ahead of state
authorization rule and streamline nationwide
oversight of online learning
 Managed by national organization (NC-SARA) and
regional compacts (NEBHE for New England states)
 When an institution is authorized in one state
(its home state), it can operate in all other
member states without any other requirements
 Institutions > Home State > Regional Compact
Summary

5. State Authorization Reciprocity Agreement (SARA)
36 Member States

6. State Authorization Reciprocity Agreement (SARA)
 Lower costs of regulatory compliance for institutions
 e.g., eliminates the need and cost to comply with 50
different states’ “patchwork” regulations of online
learning
 Increases online options for consumers
 Reduces administrative burdens on state regulators
 e.g., program review and state authorization would
be limited to in-state, physically present institutions;
 Provides minimum protections where they may not
currently exist
Benefits

7. State Authorization Reciprocity Agreement (SARA)
 Program Quality
 Only defers to accreditation
 Consumer Protection
 Requires that laws and policies inconsistent with SARA
must be amended to meet requirements
▪ MA AGO regulations for proprietary institutions (940 CMR 31)
 Few minimum protections (e.g., refund policies,
admission standards, recruitment practices)
 Complaints are forwarded to home state for resolution
▪ MA cannot prohibit an institution with multiple substantive
complaints from operating in MA
Concerns

8. State Authorization Reciprocity Agreement (SARA)
 SARA legislation filed in MA in FY17
House & Senate budgets
 2 proposed amendments would have authorized BHE to
enter into SARA
 Senate budget includes language to charge a commission
to study SARA
 USDOE expected to issue state authorization rule
Conclusion / Next Steps

9. StakeholderTestimony
Gabrielle Viator, Assistant Attorney General & Senior Policy
Advisor, Office of Attorney General Maura Healey
Margaret Mattes, Policy Associate,The Century Foundation
Michael Alexander, President, Lasell College (representing
AICUM)
John Cunningham, CEO of UMass Online;Vice President of
Academic Affairs, University of Massachusetts

10. Discussion