State Authorization for Departments
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Events
State Authorization Advisory Committee Meeting
August 23, 2023
November 2023 Email Update
February 28, 2024
What is State Authorization?
State authorization refers to federal, state and professional licensing board regulations that impact educational activities offered across state lines and programs that lead to professional licensure or certification. Authorization requirements vary by state and program and may impact university operations. At Ohio State, we have a team dedicated to researching regulations, seeking and maintaining compliance, and communicating changes in authorization status.
The Out-of-State Educational Activities policy serves as the guiding policy for the state authorization team and its units that it supports.
SARA
The State Authorization Reciprocity Agreement (SARA) is a national initiative that increases student access to distance education courses and programs while maintaining compliance with state regulations. Institutions participating in SARA can offer educational opportunities in all 49 SARA member states, the District of Columbia, the U.S. Virgin Islands and Puerto Rico without seeking individual approval in each state.
Ohio State was approved as a SARA institution in 2015. Participation expands educational opportunities for Ohio State students, decreases institutional risk, and reduces costs associated with offering Ohio State programs nationally.
SARA establishes national standards for offering interstate education, but additional approvals may be required for the following out-of-state activities:
- Out-of-state field experiences in a licensed field
- Online licensure programs
- Placements of more than 10 students per program simultaneously at a placement facility
- Establishment of a physical location
- Requiring students to meet in person
To learn more about SARA, visit nc-sara.org.
Professional Licensure & Certification Disclosure Resources
Licensure & Certification Program Inventory
Required Web Disclosures for Licensure & Certification Programs
U.S. Department of Education regulations and NC-SARA policies require institutions to disclose whether a program leading to a professional license or certification meets educational requirements for licensure or certification in all U.S. states. The Office of Distance Education and eLearning maintains central disclosure websites, and units must share the following disclosure on the licensure program webpage maintained by the unit:
Online Licensure or Certification Programs
Ohio State academic programs are designed to prepare students to sit for applicable licensure or certification in Ohio. If you plan to pursue licensure or certification in a state other than Ohio, please review state educational requirements for licensure and certification and state licensing board contact information at go.osu.edu/disclosures(link is external).
Example:
ODEE maintains online Master of Science in Nursing licensure disclosures for all 50 states on the ODEE online program disclosure website.
On-Campus Licensure or Certification Programs
Ohio State academic programs are designed to prepare students to sit for applicable licensure or certification in Ohio. If you plan to pursue licensure or certification in a state other than Ohio, please review state educational requirements for licensure and certification and state licensing board contact information at go.osu.edu/onground.
ODEE maintains Respiratory Therapy program disclosures for all 50 states on the ODEE on-campus program disclosure website.
The School of Health and Rehabilitation Sciences shares a link to the ODEE website on the Respiratory Therapy program webpage that is maintained by HRS.
Required Direct Disclosures for Licensure & Certification Programs
U.S. Department of Education regulations and NC-SARA policies require institutions to share professional licensure disclosures directly with prospective students who inquire about a program and students who enroll in a program that leads to licensure or certification. A direct disclosure can be shared via email in response to a prospective student inquiry and should be included in an acceptance email or welcome packet. Use the following templates to share direct disclosures:
Online Licensure or Certification Programs
Ohio State academic programs are designed to prepare students to apply for applicable licensure or certification in Ohio. If you plan to pursue licensure or certification in a state other than Ohio, please review state educational requirements for licensure and certification and state licensing board contact information at go.osu.edu/disclosures(link is external).
Ohio State makes every effort to ensure state licensure and certification information is current; however, state requirements may change. Please contact the applicable licensing board(s) in the state where you may want to pursue licensure or certification before beginning an academic program to verify whether a program meets educational requirements for licensure or certification in the state.
Ohio State generally does not offer online licensure or certification programs to students located in a state where the program does not meet educational requirements to apply for licensure or certification.
On-campus Licensure or Certification Programs
Ohio State academic programs are designed to prepare students to apply for applicable licensure or certification in Ohio. If you plan to pursue licensure or certification in a state other than Ohio, please review state educational requirements for licensure and certification and state licensing board contact information at go.osu.edu/onground(link is external).
Ohio State makes every effort to ensure state licensure and certification information is current; however, state requirements may change. Please contact the applicable licensing board(s) in the state where you may want to pursue licensure or certification before beginning an academic program to verify whether a program meets educational requirements for licensure or certification in the state.
Online & On-campus Licensure or Certification Programs
Has Not Determined Whether Program Meets Requirements
If the online licensure program website or the on-campus licensure program website indicate that Ohio State has not determined whether completion of the program meets educational requirements to apply for a license or certification in the state where a prospective student is located, include the following statement in the disclosure:
Ohio State has not determined whether completion of this program meets educational requirements to apply for licensure or certification in the state where you are currently located.
Program Does Not Meet Requirements
If the online licensure program website or the on-campus licensure program website indicate that completion of the program does not meet educational requirements to apply for a license or certification in the state where a prospective student is located, include the following statement in the disclosure:
Completion of this program does not meet educational requirements to apply for licensure or certification in the state where you are currently located.
State Authorization Resources
Out-of-State Educational Activities Policy
The Out-of-State Educational Activities Policy aims to bring Ohio State into compliance with state authorization regulations and positively impacts faculty, staff, and students.
The policy defines state authorization roles and outlines compliance processes. By following compliance processes, units can ensure that an Ohio State degree will be recognized and that a student will be eligible to sit for licensure in another state.
International Online Enrollment Information
Online International Enrollment Disclosure
If your program decides to enroll an international student in an online course or program, the state authorization team requests that you provide a written disclosure statement to the student. Sample disclosure notification:
A country may or may not regulate distance education provided to students in its jurisdiction and may or may not require foreign higher education institutions to comply with distance education regulations. At this time, The Ohio State University cannot guarantee that a program meets curriculum requirements or professional licensure requirements in your country.
To learn more, view international enrollment considerations.
NC-SARA Resources and Information
Out-of-State Physical Presence Activity Resources
Colorado Workers' Compensation Requirements - Unpaid Interns
The Colorado Workers' Compensation Act requires unpaid student interns to be covered by workers' compensation insurance. Specifically, Colorado Revised Statute 8-40-302 states:
(7) (b) If the student placed in an on-the-job training program does not receive any pay or remuneration from the employer, the educational institution sponsoring the student in the cooperative education or student internship program shall insure the student through the institution's workers' compensation and liability insurance or enter into negotiations with the employer for the purpose of arriving at a reasonable level of compensation to the employer for the employer's expense of providing workers' compensation and liability insurance while such student is participating in on-the-job training with said employer. This paragraph (b) shall not apply to a student teacher participating in a program authorized pursuant to article 62 of title 22, C.R.S.
(c) As used in this subsection (7), "cooperative education or student internship program" means a program sponsored by an educational institution in which a student is taught through a coordinated combination of specialized in-the-school instruction provided through an educational institution by qualified teachers and on-the-job training provided through a local business, agency, or organization or any governmental agency in cooperation with the educational institution.
Q: Can I complete a field experience in Colorado?
A: Yes, but prior to beginning a field experience at a Colorado facility, you should work with your internship coordinator to ensure that Colorado worker's compensation insurance requirements are met.
The Colorado Workers' Compensation Act requires unpaid student interns to be covered by workers' compensation insurance. Ohio State is not able to add students to its institutional workers' compensation policy and students may not provide their own workers' compensation insurance.
State Authorization Liaison Information
State Authorization Advisory Committee (SAAC) Charter
State Authorization Advisory Committee (SAAC) Members
| Name | Title | Unit |
|---|---|---|
| Ericka Bruce | Program Manager — Education | College of Medicine |
| Gina Taff | College Registrar | College of Nursing |
| Nancy Dugan | Director — Career Development | College of Education and Human Ecology |
| Carri Gerber | Assistant Director — Academic Affairs | CFAES — ATI |
| Carson Fort | D.C. Academic Program Manager | John Glenn - Washington D.C. |
| Ryan Hunt | Associate Registrar | University Registrar |
| Jeremie Smith | Distance Education Coordinator | College of Arts and Sciences |
| Vicki Miller | Associate Director — Compliance | Student Financial Aid |
| Marcia Nahikian-Nelms | Director of Academic Affairs | School of Health and Rehabilitation Sciences |
| Paul North | Executive Director Graduate Programs | Fisher College of Business |
| Ansel Oakleaf | Online Education Data Specialist | Office of Distance Education and eLearning |
| Jeanne Osborne | Assistant Dean — Academic Affairs | CFAES |
| Ruby Pentsil-Bukari | SEVIS Analyist and Compliance Officer | Office of International Affairs |
| Richard Fajardo | Career Development Coordinator | CFAES |
| Byron Roush | Director — Instructional Design | College of Social Work |
| Elizabeth Vu | Sr. Distance Learning Coordinator | College of Arts and Sciences |
| Dawn Williams | Assistant Director, Student Affairs | College of Public Health |
| Vacant |
State Authorization Advisory Committee (SAAC) Meeting Notes
Federal State Authorization Regulations
Program Integrity Rules - Misrepresentation (34 CFR 668.71 and 668.72(c))
Federal State Authorization Regulation (34 CFR 600.9 and 668.43), effective July 1, 2020
Frequently Asked Questions
SARA
Q: Is every state a member of SARA?
A: No, SARA membership is voluntary. Currently, California is the only state that does not participate in SARA.
Q: Does Ohio State’s SARA participation automatically renew?
A: Ohio State is required to complete a renewal application every year to continue participation in SARA. The Office of Distance Education and eLearning pays the annual $12,000 SARA renewal fees on behalf of the institution.
Q: What if a program would like to place more than 10 students simultaneously at a facility?
A: If a program would like to place more than 10 students at a time at a facility in a SARA state, the state authorization team will reach out to the state SARA portal entity to request permission prior to the placement.
State agencies want to ensure that resources are available for all institutions placing students in the state. If a SARA portal entity doesn’t grant approval to place more than 10 students at a site, Ohio State could seek authorization from the state higher education regulator to move forward with the placement.
Q: When is Ohio State required to submit the annual report to NC-SARA?
A: Ohio State reports out-of-state student location information to NC-SARA between May 15 and June 15 each year. NC-SARA requires institutions to report the number of students participating in online programs and on-ground field experiences in each state during the previous year.
The state authorization team facilitates collection of student placement data in spring semester.
Q: Where can I learn more about NC-SARA requirements and policies?
A: Learn more at nc-sara.org and review the NC-SARA Manual.
Marketing, Advertising and Recruiting
Q: Can a program advertise or recruit in a SARA state without additional approvals?
A: Yes. SARA covers advertising and recruiting activities in all SARA states. This includes recruitment at college fairs, and covers recruitment for traditional or online programs.
Advertising and recruiting materials must meet SARA guidelines for accuracy and truthfulness, including: accuracy of job placement data and information regarding tuition, fees and financial aid, admission requirements, professional licensing requirements, accreditation, and transferability of course work to other institutions.
Q: What do I need to know about advertising or recruiting in non-SARA states or territories?
A: States that do not participate in SARA may have laws that restrict or prohibit advertising and recruiting. For example, some states may allow recruiting, but require the recruiting agent to be registered. Some states allow occasional recruiting, but prohibit consistent, organized recruiting.
Review the Physical Presence Activities by State document to learn more about advertising or recruiting in non-SARA states.
Q: What are college and unit responsibilities regarding out-of-state advertising, marketing and recruiting?
A: Colleges and units should be aware of and comply with state advertising and recruiting requirements and should contact the state authorization team with questions.
Out-of-State Placements and Internships
Q: Can students be placed in a SARA state without additional state approval?
A: Generally, yes. Up to ten students per program per facility may be placed simultaneously in a SARA state. For licensure programs, additional approval may be required from the state professional licensing board.
Contact the state authorization team for more information about licensure program placements or placing more than 10 students per program at a facility in a SARA state.
Q: What are college and unit responsibilities regarding out-of-state student placements?
A: Colleges and units should review placement restrictions in each state and consult with their state authorization liaison and the state authorization team prior to placing a student outside Ohio. Colleges and units must seek professional licensing board approval of a placement if necessary.
In addition, colleges and units are responsible for tracking the location of out-of-state student placements. The state authorization team collects this data for NC-SARA reporting in spring semester.
Colleges or units should also report any out-of-state student placements that have not been previously reported to the state authorization team. This information helps the state authorization team prioritize authorization efforts.
Out-of-State Professional Licensure
Q: Does SARA cover professional licensing board approvals in SARA member states?
A: No. Although SARA covers many out-of-state activities, it does not include professional licensing board approvals that may be required for out-of-state activities that are part of a licensure program.
Q: Which programs require professional licensing board approval?
A: Requirements vary from state to state. Some licensing boards require approval of pre-licensure and post-licensure programs. Other boards may require faculty to be licensed in the state where the student is located. Or boards may not regulate out-of-state programs at all.
Q: How does Ohio State make students aware of licensure requirements in other states?
A: The Office of Distance Education and eLearning maintains professional licensure and certification disclosures for online programs and on-campus programs on central disclosure websites. Colleges and units are required to link to ODEE's central disclosure websites on the licensure or certification program webpage maintained by the college or unit and must provide direct email disclosures to students.
Colleges and units can use OAA's web disclosure and direct disclosure templates to share required disclosures with prospective students.
Q: What are college and unit responsibilities regarding out-of-state professional licensure?
A: Colleges and units must research and seek approval from the appropriate professional licensing board for a licensure program that includes an out-of-state activity, such as a clinical experience. Colleges or units should work with their state authorization liaison and the state authorization team to seek and maintain any required licensing board approvals.
Colleges and units should submit documentation of licensing board approvals to the state authorization team via email.
Q: Are there consequences for not disclosing professional licensing board status to students?
A: Possible consequences for non-compliance or misrepresentation of program status range from student lawsuits, loss of federal financial aid eligibility, fines, loss of accreditation, and negative institutional reputation.
Role of the State Authorization Advisory Committee
Q: Does the SAAC approve programs to engage in out-of-state educational activities?
A: No, the SAAC does not approve or disapprove out-of-state activities. Rather, the SAAC reviews out-of-state physical presence activities to evaluate risk and prioritize next steps in seeking authorization. The committee will analyze new state authorization issues that arise and communicate next steps to state authorization liaisons.
Q: Who serves on the Committee?
A: The committee is comprised of faculty, deans, students, and representatives from impacted units and colleges. The SAAC is convened by the state authorization team.
Q: When does the SAAC meet?
A: The SAAC meets on a quarterly, or as-needed, basis.
Q: Who can serve on the SAAC?
A: Ohio State faculty, staff and students can self-nominate or may nominate a colleague to serve on the State Authorization Advisory Committee. To submit a nomination, reach out to the state authorization team.
Role of the State Authorization Team
Q: Does the state authorization team approve or disapprove out-of-state trigger activities?
A: No, the role of the state authorization team is not to approve or disapprove out-of-state activities. Rather, the team educates colleges and units about the risks associated with operating in a state without authorization.
Q: What are college and unit responsibilities to the state authorization team?
A: Colleges and units should report out-of-state educational activities to the state authorization team and their state authorization liaison. This information will be used to prioritize authorization efforts.
The state authorization team facilitates collection of out-of-state placement information for the annual NC-SARA report. Colleges and units should continuously track this information and provide updated data to the state authorization team each autumn.
In addition, the state authorization team occasionally requests information about curriculum, faculty, recruiting, or marketing activities. Colleges and units should provide this information to the state authorization team to facilitate authorization efforts.
Q: What is the difference between the state authorization team and the State Authorization Advisory Committee (SAAC)?
A: The state authorization team is responsible for seeking all necessary state and territory authorizations on behalf of the university. The team educates colleges and units about state authorization requirements and works with liaisons to collect reporting data and information required for authorization applications.
The SAAC is convened by the state authorization team and prioritizes authorization efforts after reviewing university risks and needs. In the event an adverse action related to state authorization is filed against the university, the SAAC communicates information and next steps to impacted colleges and units.
Role of the State Authorization Liaisons
Q: Who acts as the state authorization liaison for a unit?
A: State authorization liaisons are appointed at the associate dean level and serve as the point of contact for their unit.
Q: Does the state authorization liaison approve trigger activities for their unit?
A: No, the state authorization liaison does not approve or disapprove physical presence activities. The state authorization liaisons work with the state authorization team to educate their units regarding state authorization requirements for conducting physical presence activities.
Q: What are the responsibilities of a state authorization liaison?
A: State authorization liaisons serve as the point of contact for their unit. Liaisons are responsible for submitting physical presence activities as needed and reporting student placement data annually to the state authorization team.
Liaisons educate their units regarding state authorization regulations, and with the State Authorization Advisory Committee, determine a unit-specific action plan for participating in physical presence activities outside Ohio. See the state authorization liaison position description for more information.
Authorization Map
Find out where Ohio State is authorized to offer out-of-state educational activities.
Note: Additional approval may be required for 1) field experiences in a licensure field, and 2) placements of more than 10 students per program at a single facility, such as a hospital. Contact the state authorization team for more information.
International Enrollments
Risk Assessment
Distance education regulations vary by country. It is the decision of the college or department whether to enroll an international online student. If your program decides to enroll an online student located outside the U.S., we request you advise the student to understand online program regulations in their country (see below).
If a student located outside the U.S. wishes to enroll, please share this disclosure prior to enrollment:
A country may or may not regulate distance education provided to students in its jurisdiction and may or may not require foreign higher education institutions to comply with distance education regulations. At this time, The Ohio State University cannot guarantee that a program meets curriculum requirements or professional licensure requirements in your country.
International Enrollment Considerations
Foreign Degree Recognition
Some countries do not currently recognize credentials earned online
Foreign Tax Requirements
Some countries seek to tax students and institutions directly. Students should be aware of potential taxes that may be charged in addition to tuition.
Countries Subject to U.S. Sanctions
Some countries may be subject to comprehensive or limited sanctions. Depending on the sanction category, providing educational services may be prohibited.
Specially Designated Nationals (SDN) List
Some individuals and companies owned, controlled by, or acting for or on behalf of certain countries cannot receive services from U.S. entities. Coursework and most university activities are exempt.
Internet Access Issues
Some countries (e.g., China) block or filter internet content. Use of a VPN in China is generally restricted and is not reliable.
Data Security and Privacy
Many countries have stronger data privacy laws than the U.S.
Canada Distance Education Authorization Requirements
Similar to U.S. states, Canadian distance education regulations vary by province and territory.
Note that Canadian professional licensure agencies may have additional requirements for Ohio State to offer a licensure program to students located in Canada. Programs should contact the agency to verify requirements prior to enrolling students.
Alberta Ministry of Advanced Education
Authorization is not required to offer 100% online programs or on-ground field experiences in Alberta.
British Columbia Ministry of Advanced Education, Skills & Training
Authorization is not required to offer 100% online programs. Authorization is required to place a student in an on-ground field experience in British Columbia. University direct advertising is restricted.
Manitoba Post-Secondary Education & Workforce Development Division
Authorization is not required to offer 100% online programs or on-ground field experiences in Manitoba. University direct advertising is restricted.
New Brunswick Post-Secondary Education, Training & Labour
Authorization is not required to offer 100% online programs or on-ground field experiences in New Brunswick.
Newfoundland/Labrador Advanced Education, Skills & Labour
No information available.
Northwest Territories Adult & Post-Secondary Education Unit
Authorization is not required to offer 100% online programs or on-ground field experiences in the Northwest Territories.
Nova Scotia Labour & Advanced Education
Authorization is not required to offer 100% online programs. Authorization is required to place a student in an on-ground field experience in Nova Scotia.
Nunavut Department of Education
Authorization is not required to offer 100% online programs or on-ground field experiences in Nunavut.
Ontario Ministry of Training, Colleges & Universities
Authorization is not required to offer 100% online programs. Authorization is required to regularly place students in on-ground field experiences in Ontario and to directly advertise programs to prospective students located in Ontario.
Prince Edward Island Post-Secondary & Continuing Education
Authorization is not required to offer 100% online programs. Authorization is required to place a student in an on-ground field experience in Prince Edward Island.
Quebec Ministry of Education & Higher Education
Authorization is not required to offer 100% online programs. Authorization is required to place a student in an on-ground field experience in Quebec. University direct advertising is restricted.
Saskatchewan Ministry of Advanced Education
Authorization is not required to offer 100% online programs or on-ground field experiences in Saskatchewan.
Yukon Department of Education
Authorization is not required to offer 100% online programs. Authorization is required to place a student in an on-ground field experience in Yukon.
Australia Distance Education Authorization Requirements
Tertiary Education Quality & Standards Agency
Authorization is not required to offer 100% online programs to students located in Australia.
Contact Us
stateauth@osu.edu
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