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State Authorization Reciprocity Agreement (SARA)

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Overview

The State Authorization Reciprocity Agreement (SARA) is an agreement among the regional education compacts  (SREB, WICHE, MHEC, and NEBHE) and their member states through which participating institutions may offer distance education to students located in other member states without having to obtain separate, individual authorization from each state in which a student is located.

State Membership

State membership in SARA is voluntary. Currently, 49 states (California is the only non-member state), the District of Columbia, and the U.S. territories of Puerto Rico and the U.S. Virgin Islands are members. Each member state designates a state agency that is responsible for administering SARA within its borders and approving in-state institutional applications for participation. The Oklahoma State Regents for Higher Education (OSRHE) is Oklahoma’s State Portal Entity (SPE).

Institutional Participation

Only institutions located in member states can participate. Institutional participation is voluntary and available only to degree-granting institutions that are accredited by an accreditor recognized by the U.S. Department of Education. For and nonprofit, private and public institutions are eligible to participate. Institutions must be approved annually by the SPE of the state in which their principal campus or central administrative unit is legally domiciled.

Institutional Eligibility

Oklahoma institutions may only be approved for SARA participation if they fulfill the requirements of NC-SARA and in the OSRHE policy. Eligibility requirements can be found on the NC-SARA website  and in the OSRHE State Authorization Reciprocity Agreement policy. Institutions are advised to review these requirements prior to submitting an application. For questions about eligibility for participation, email Ms. Elizabeth Walker.

Institutions that do not choose to participate or are not eligible to do so may still offer distance education to students in other states; however, they must obtain authorization individually from each state in which their students are located.

Institutional Resources and Staff Support

NC-SARA provides extensive support and professional development opportunities related to distance education and SARA participation to staff of participating institutions. See the SARA Learning Station for details and resources, including the SARA Institution Welcome Kit and more.

Procedures

Non-Title IV Institutions

All SARA policy and OSRHE SARA policy apply equally to institutions that do not participate in Title IV funding.

Apply to Participate in SARA

To apply for OSRHE approval to participate in SARA, public and private Oklahoma institutions must submit a completed SARA application form to the OSRHE office, pay the NC-SARA institutional participation fee, and operate according to the requirements in the application form and the SARA Policy Manual. Participation must be renewed annually through the same process.

  1. Complete the Oklahoma SARA Application Supplement (DOCX, 65k). (Clicking the link will not open a document or webpage, it will download the supplement to your browser’s downloads folder.)
  2. Complete the NC-SARA application. Always use the most recent application form, available on the Applications and Approval Forms page of the NC-SARA website.
  3. Gather any documentation required by either form.
  4. Email the above items to Elizabeth Walker.
  5. On receipt of the application forms and documentation, State Regents’ staff will review the submission for compliance with NC-SARA and OSRHE policy.

Applications that are non-compliant are returned to the institution with information about what is needed to correct the non-compliance. State Regents’ staff will take no further action on a returned application until a correct one is received. Compliant applications are approved, pending State Regents’ ratification at their next meeting, and a letter is generated from the OSRHE office to the institutional president documenting the approval.

State Regents’ staff enter the information provided in the application into the NC-SARA Salesforce institutional database and indicate in Salesforce that the application is approved. The institution’s contacts provided in the application receive an email from NC-SARA with a link to the fee invoice and an option to pay it electronically.

When NC-SARA receives the fee, the institution’s one-year SARA participation begins. NC-SARA includes the institution in its list of participating institutions and sends an email to the institutional contacts with information about SARA participation and a link to the SARA participation seal with instructions on how to use it on the institution’s website. State Regents’ staff is cc’d on this email.

Apply to Renew Participation in SARA

Renewal Cycle

A SARA-participating institution’s initial approval is for one year, ending on the anniversary of the date its initial approval payment was received by NC-SARA. This is the institution’s participation end date, and participation must be renewed each year prior to that date.  This date does not change so long as the institution renews on time every year, regardless of when the renewal application is approved or the institution pays the SARA participation fee. For example, if the participation end date is Aug. 3, and the institution pays for its renewal on June 20, the participation end date for all subsequent years is Aug. 3.

Process

Ninety days before an institution’s annual participation end date, the institution’s contacts receive an email notice from NC-SARA that the institution has entered its renewal period, with renewal instructions and a link to the Applications and Approval Forms page of the NC-SARA website.

The institution applies to renew its participation through the same process as above. Renewal applications must be received by State Regents’ staff 30 days prior to the institution’s participation end date. Any application that is received after that date MAY NOT BE REVIEWED AND APPROVED BEFORE the participation end date. The participation of an institution that is not approved in Salesforce before the participation end date lapses on that date and may not be renewed until after 180 days has passed.

SARA Participation Fees

NC-SARA charges institutions an annual participation fee for initial and annual renewal based on the institution’s FTE. To find the current fee structure, see NC-SARA | Participation Fees. OSRHE does not assess any additional fees.

Update Institutional Contacts

NC-SARA communicates important information to institutions about their participation through the institutional contacts stored in the Salesforce database. Institutional contacts are required in both initial and renewal applications, but sometimes an institution’s contacts will change long before a renewal application is due.

When this happens, the institution must promptly notify State Regents’ staff of the change in institutional contact. Complete the Oklahoma Institution Contacts Change Form (DOCX, 70k) to submit changes in contact information. (Clicking the link will not open a document or webpage, it will download the supplement to your browser’s downloads folder.) Email the completed form to Ms. Elizabeth Walker.

Do not email this information to NC-SARA. They will reply to you with the request that you send it to OSRHE.

Catastrophic Events/Disaster Recovery

All SARA-participating institutions shall maintain a catastrophic event/disaster recovery plan. The plan shall be reviewed and updated on a defined periodic basis, for example, every two years. The institution shall provide a copy of the plan or a summary thereof to the OSRHE upon request.

The institution’s catastrophic event/disaster recovery plan shall fulfill its accreditor’s requirements, and additionally provide, at a minimum, policies and procedures to ensure that when the institution discontinues a program offered through SARA, closes a site or branch campus from which distance education is delivered through SARA, or closes the institution due to a catastrophic event:

  1. Students will receive the services for which they have paid or reasonable financial compensation for those not received through teach-out plans, transfer agreements, student tuition recovery reimbursements or forgiveness, or other similar student-support measures.
  2. Academic transcripts will be preserved and student access to them will continue during and after the catastrophic event or related closure of a site, branch campus, or the institution.

Removal From or Nonrenewal of Participation

Consistent with SARA policy, the OSRHE will remove from participation or not approve for renewal an institution if:

  1. It fails to renew its participation under the terms of the SARA Policy Manual.
  2. It fails to pay its annual fees as required in the SARA Policy Manual.
  3. It loses or withdraws from institutional accreditation by a USDE-recognized accreditor.
  4. Its federal financial responsibility composite score falls below 1.0.

An institution that has been removed from or not renewed for participation will receive written notification from OSRHE that will include the reasons for the removal or nonrenewal and, as applicable, the removal effective date, the teach-out end date, the date all references to SARA participation shall be removed from the institution’s website, and any further removal or nonrenewal implementation instructions.

An institution that is removed or not approved for renewal:

  1. Shall follow the instructions in the OSRHE removal notification.
  2. Shall remove all references to SARA and the SARA logo from its website, catalog, handbook and other related materials by the date specified in the removal notification (within 90 days of the removal effective date).
  3. Shall receive no refund or reimbursement of any fees paid to SARA.
  4. May enroll no further students through its former SARA participation.
  5. Is no longer a SARA participant and must meet the state authorization requirements of each state where any students are enrolled or admitted after the removal effective date.

Teach-Out End Date

Students who were enrolled at the institution prior to receipt of the removal notification may continue their studies at the institution under SARA authorization through the teach-out end date specified in the removal notification (180 calendar days from the removal effective date). The day after the teach-out end date, the institution is not authorized through SARA to offer distance education to students in other states regardless of the student’s enrollment status on or before the removal effective date.

Appeal Removal or Nonrenewal

Consistent with SARA policy, institutions removed from participation or not approved for renewal may appeal the removal or nonrenewal. To do so, email a request to appeal to Ms. Elizabeth Walker.

Post-SARA Activity

Oklahoma SARA-participating institutions that have been removed from or nonrenewed for SARA participation must meet non-SARA state requirements in states where any new students are admitted after removal or non-renewal.

Disclosure and Notification Requirements

Consistent with SARA policy, the following disclosures are required of all Oklahoma SARA-participating institutions.

Adverse Action

All SARA-participating institutions shall notify the OSRHE of any adverse action* against it by an oversight entity related to its academic quality, financial stability, student consumer protection policies or practices, or compliance with state or federal laws or regulations, within 30 calendar days of the institution’s first knowledge of the action or investigation.

To notify the OSHRE of an adverse action, email the following information to Ms. Elizabeth Walker:

  • That the institution has received an adverse action.
  • A copy of the notice of the action from the oversight entity.
  • A summary of steps the institution will take to resolve the action or investigation.
  • A copy of all correspondence between the oversight entity and the institution regarding the adverse action and the institution’s progress in resolving the cause of it.

Consistent with SARA policy, the adverse action may result in the institution’s SARA participation being placed in provisional status until the cause of the adverse action is resolved. Failure to report any such action or investigation may result in the institution being removed from SARA participation.

*“Adverse action” means: a warning or sanction issued by the institution’s accrediting agency, the U.S. Department of Education, a professional licensing board, or a state regulatory entity; a judgement against an institution that includes a finding of a consumer protection violation or that may impact ongoing operations; or any action, decision, or finding that impacts the institution’s financial solvency.

Changes in Operations

Institutions shall disclose to the OSRHE any changes in the institution’s operations that are inconsistent with the requirements contained in the SARA Policy Manual or that may impair the institution’s ability to satisfy any requirement of the SARA Policy Manual within 30 days of the institution’s first knowledge of the change. To notify the OSRHE of a change in operations, email Ms. Elizabeth Walker.

Composite Score

A private participating institution that determines or is notified by an entity other than OSRHE that its federal financial responsibility composite score has changed shall report the change to the OSRHE within 30 calendar days of its determination or receipt of the notification, with any documentation related to the change in score. To report a change in composite score, email notification of the change and related documentation to Ms. Elizabeth Walker.

Provisional Status

An institution that is participating in SARA under provisional status shall disclose that status on its webpage, and any references to the institution’s participation in SARA on its website shall include a disclaimer that the institution’s participation is provisional.

Should OSRHE place an institution into provisional status, the institution will receive written notification from OSRHE that will include the reasons for the status, its effective date, requirements and the deadline for the website disclosure and disclaimers (10 calendar days from receipt of notification), and information about what the institution must do to regain full participation.

Professional Licensure Programs

Any institution approved to participate in SARA that offers courses or programs designed to lead to professional licensure or certification or advertised as leading to licensure must satisfy all federal requirements for disclosures regarding such professional licensure programs.

Current federal regulations regarding interstate offering of professional licensure programs can be found at 34 CFR 668.14 (b)(32) and 34 CFR 668.43 (a)(5)(v).

Student Complaint Information

SARA-participating institutions are required to post information about SARA’s student complaint policies and procedures on the institution’s website where it is easily accessible to students attending the institution through SARA, and in the institution’s catalog or equivalent information provided either in print or electronically to students when they enroll. The information provided shall contain at a minimum:

  1. A clear explanation of the institution’s own complaint/grievance process and appeal process. This can be the same process/information the institution provides to its Oklahoma (non-SARA) students.
  2. A form or email address for students to submit complaints directly to the person or office that will respond to the complaint. This can be the same process/information the institution provides to its Oklahoma (non-SARA) students.
  3. That students attending your institution through SARA can appeal the institution’s resolution of a SARA-related complaint to the OSRHE or to the SARA State Portal Entity of the state where the student is located. (Do not recommend the student appeal a complaint resolution to NC-SARA. NC-SARA does not accept student complaints or appeals.)
  4. These links:

See SARA Student Complaints and Consumer Protection below for OSRHE SARA student complaint and appeal procedures.

Teach-Out Plans

A SARA-participating institution that is required to submit an institutional teach-out plan, teach-out agreement, or any other closure-related plan with an accrediting agency, authorizing entity, or the USDE shall simultaneously provide OSRHE a copy of:

  • The plan or agreement including all related documentation from the requesting agency.
  • Documentation of all follow-up regarding the required submittal generated by the institution and the requesting agency.
  • Any additional information requested by OSRHE.

Personally identifying information shall not be included in any submission to OSHRE. Provide the required information by email to Ms. Elizabeth Walker.

Closure of a SARA-Participating Institution

A SARA-participating institution that is closing a site, branch campus or the entire institution shall notify OSRHE of the impending closure immediately upon the decision to close by email to Ms. Elizabeth Walker.

During the closure process, the institution shall provide OSRHE copies of correspondence between the institution and its accreditor regarding the closure, including, but not limited to, plans for student teach-out, transfer agreements, maintenance of student records, and any other action whereby the institution assures that students receive the services for which they paid or reasonable financial compensation for those not received.

SARA Student Complaints and Consumer Protection

SARA Student Complaints

As the SARA State Portal Entity for Oklahoma, OSRHE has authority to review and investigate an appeal of an institution’s resolution of a complaint against a SARA-participating Oklahoma institution if the complaint:

  • Alleges the institution has violated or acted out of compliance with the provisions of the SARA Policy Manual.
  • Is submitted to OSRHE within two years of the incident about which the complaint is made (complaint appeals submitted to OSRHE more than two years after the incident about which the complaint is made will not be reviewed).
  • Has been pursued within the institution to the highest institutional administrative level available.
  • Does not concern an institutional decision regarding grades or student conduct violations (institutional decisions concerning complaints about grades or student conduct violations are not eligible for review by OSRHE).
  • Does not concern an institution’s violation of federal laws related to discrimination or harassment. Such complaints should be reported to the institution’s Title IX coordinator or the U.S. Department of Education’s Office for Civil Rights.
  • Is submitted by a SARA student.

A SARA student is a student who is enrolled in and attending an exclusively distance education program or course offered by a SARA-participating institution, and who is living or located in a state other than the institution’s home state while attending the program coursework.

Exclusively distance education means a course or a program for which the instructional content is delivered exclusively via distance education, with no requirement to take any course or elective necessary to complete the program in person, except for any supervised field experiences (either required or elective, including those for which credit is individually awarded) or requirements for in-person attendance for orientation, testing, or academic or student support services.

A SARA student who feels the institution has not appropriately addressed a complaint that fulfills all the conditions above may submit an appeal of the institution’s resolution of their complaint through the SARA Student Complaint Review Request Form.

On receipt of a complaint appeal, OSRHE will open an investigation which will include, but not be limited to, contacting the institution for information about its resolution of the complaint, notifying the SARA SPE of the state in which the student lived at the time of the complaint, and contacting any other agency, organization, or involved party as appropriate during investigation.

If the institution is found to be out of compliance with SARA policy, OSRHE will take appropriate action to bring the institution back into compliance, up to and including removing the institution from SARA participation. OSRHE will notify the SPE of the state in which the student lived at the time of the complaint of its final determination of the appeal. If the institution’s actions and resolution of the complaint are found to be in compliance with SARA policy, the complaint and appeal will not be eligible for further review or action by OSRHE. The OSRHE’s determination regarding the complaint appeal will be final.

For more information about SARA student complaints and appeals, see NC-SARA | Student Complaints.

Oklahoma Student Complaints

Oklahoma students attending an out-of-state institution through its participation in SARA who believe that the institution they are attending is operating out of compliance with SARA policy  must follow the student complaint or grievance policy within the institution to the highest administrative level available. After this process is complete, students who feel the institution did not appropriately address the complaint may appeal the institution’s resolution of the complaint to the SARA State Portal Entity (SPE) for the state in which the institution is located. For a list of SPEs for all SARA member states, see NC-SARA | SARA State Portal Entity Directory. The student may also request assistance in contacting the institution’s home state SPE by email to Ms. Elizabeth Walker.

Consumer Protection

Consistent with SARA policy, OSRHE will investigate and resolve allegations of dishonest or fraudulent activity by Oklahoma SARA-participating institutions. Examples of consumer protection issues under this provision include but are not limited to:

  1. Veracity of recruitment and marketing materials;
  2. Accuracy of job placement data;
  3. Accuracy of information about tuition, fees, and financial aid;
  4. Accuracy and completeness of information about admission, retention, and graduation requirements for courses and programs;
  5. Accuracy of information about the institution’s accreditation and/or any programmatic/specialized accreditation held by the institution’s programs;
  6. Accuracy of information about whether coursework meets any relevant professional licensing requirements or the requirements of specialized accrediting agencies;
  7. Accuracy of information about whether the institution’s coursework will transfer to other institutions; and
  8. Operation of distance education programs consistent with practices expected by institutional accreditors (and, if applicable, programmatic/specialized accreditors).

These issues concern accuracy, completeness, and veracity of communication of the information provided by the institution, not what the information is. For example, that an institution indicated a tuition amount prior to enrollment, then charged the student a different amount after enrollment, would constitute a consumer protection issue. The amount of tuition the institution charges does not.

Discrimination or Harassment

Any allegations regarding an institution’s violation of federal laws related to discrimination or harassment do not constitute consumer protection issues under this provision. Such allegations should be reported to the institution’s Title IX coordinator or the U.S. Department of Education’s Office for Civil Rights.

Students wishing to report a consumer protection issue may do so by email to Ms. Elizabeth Walker.