State to State Institutional Approval for Distance Education Handbook

Implementation Handbook for Institutions Seeking State-to-State Authorization to Offer Interstate Activities 

Summary – 

This Handbook guides institutions that do not participate in interstate reciprocity through the State Authorization Reciprocity Agreement (SARA) in developing a compliance plan to offer activities to students located outside the institution’s home state.

States vary in their oversight of higher education activities in their state.  Institutions are responsible for complying with any statutes or regulations to offer activities in the state where students are located.  Additionally, to participate in Title IV Federal Financial Aid programs, Federal regulation requires that the institution must be compliant with any state requirements to offer distance education where students are located.  While reciprocity through SARA provides this compliance for institutions participating in SARA, institutions that do not participate in SARA must meet compliance requirements from state to state.

Please note that institutions must determine where the student is located when participating in the activities of the institution – this is different than their residence.

Contents – 

• Foundational Elements
• Development of Institutional Processes to Research, Analyze, Communicate, and Maintain Information
• Conclusion
  • Appendix A. Examples of Possible Documentation Requirements for Applications
  • Appendix B. Checklist of Institutional Steps to Research, Analyze, Communicate and Maintain Information
  • Appendix C. General Practice Tips
  • Appendix D. Example of Progress Chart
  • Appendix E. Resources

Details

• Year Published: 2025
• Month Published: August
• Media Type: pdf

Author:

Shari Miller, Institutional Compliance MATTERS

Contributor:

Cheryl Dowd, Senior Director, State Authorization Network & WCET Policy Innovations

Reviewer:

Jana Walser-Smith, Former Director, Interstate Compliance and SAN Member Outreach