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Draft St. Authorization Reciprocity Agreement Ready for Input

Russ Poulin, deputy director for research and analysis at the WICHE Cooperative for Educational Technologies (WCET), has announced that a draft State Authorization Reciprocity Agreement (SARA) is ready for public review and feedback. As a member of the drafting team working in a process organized by The Presidents' Forum and the Council of State Governments, Poulin has provided a great summary of the agreement's key provisions and requested that interested members of the higher education community, particularly those engaged in the development and delivery of e-learning, review the draft in full and submit ideas and recommendations for the drafting team to consider. Once the draft is finalized, the Council of State Governments will submit it to state legislatures for consideration and adoption. States adopting the final agreement will join a compact in which an institution's authorization by its home state to offer postsecondary education, including online/distance education, will allow it to meet the authorization requirements of all other SARA states (excluding programs leading to professional licensure, such as nursing, where separate state processes and authorities may apply). This will allow institutions in SARA states to provide online/distance learning to students across those states without incurring the costs and potential risks of trying to achieve and maintain compliance with all of the postsecondary education authorization provisions of each individual state. However, institutions in SARA states that deliver online/distance education in non-compact states will have to separately manage compliance with those states' requirements, and institutions in non-SARA states will have to individually manage all of the state authorization processes of the states in which they operate.

The draft agreement envisions the creation of a SARA Policy Board with a small administrative staff to manage state and institutional participation in relation to the compact. This includes the levying of institutional fees to address state regulatory costs associated with students in a state that are being served by an out-of-state provider as well as the cost of maintaining the Policy Board and staff. The fiscal model for the agreement (see pp. 2-10 of Appendix A) provides an initial, rough estimate of approximately $7,000 per year per institution in SARA fees, as well as an additional $1,000 per year in possible fee increases from an instituiton's home state to address its regulatory costs. While clearly a back-of-the-envelope calculation at this point (your actual mileage may, and probably will, vary), the draft highlights that even if institutions found themselves paying double this amount, their costs would still be a small fraction of the upwards of $100,000 per institution to achieve state authorization compliance across the country that some estimates indicate. Of course, how much less an institution's full cost of state authorization compliance might be will depend on the number of states joining SARA and the proportion of SARA to non-SARA states in which it provides online/distance learning.