91´ÎÔª

STATE AUTHORIZATION RECIPROCITY AGREEMENT (SARA) 

The State Authorization Reciprocity Agreement (SARA) is a national initiative to provide more access to online courses while maintaining compliance standards with state regulatory agencies. SARA allows institutions to provide online courses outside of their own state borders by seeking and maintaining state approvals via a streamlined process. To learn more about SARA, please visit:

A "State Authorization Reciprocity Agreement" is an agreement among its member states, districts and U.S. territories that establishes comparable standards for offering postsecondary distance education courses and programs. Participation in SARA provides UM with authorization to provide postsecondary distance education to students in other States and territories covered by the agreement.

Limitations: SARA applies only to distance education activities conducted across state lines. SARA does not affect the applicability of general-purpose state laws such as business registries, general-purpose consumer protection laws, worker’s compensation laws and the like. SARA also does not affect the applicability of state professional licensing or other regulatory agency requirements. 

UM Designated NCSARA Contact 

The 91´ÎÔª is a member of NC-SARA. If you have questions about NC-SARA please reach out to Eric Vorkoeper. 

In compliance with U.S. Department of Education regulations and as an institution participating in the State Authorization and Reciprocity Agreement (SARA), the 91´ÎÔª is required to maintain specific information regarding its programs designed to meet the educational requirements for a specific professional licensure or certification required for employment in an occupation. UM is also required to disclose this information to prospective and current students about whether program completion would meet state and/ or state licensing board requirements in any given U.S. state or territory, for each of its programs designed to meet the educational requirements for a specific professional licensure or certification required for employment in an occupation. 

If you plan to pursue employment in a licensed profession, it is important to understand state and/or state licensing board requirements. Please consult our Professional Licensure website for more information 

The Student Location Determination Policy can be reviewed on the UM Operating Policies website. 

Institutional Procedures  

1. Professional Licensure/ Certification Cohorts: UM will determine the location of a student for the purposes of providing professional licensure disclosures in the following ways: 
   1. Prospective Students: The Permanent Address§ submitted by students via the Customer Relationship Management (CRM) admissions platform will be used for the purposes of determining a prospective student’s physical location. 
   2. Current Students/ Relocating Students: The Permanent Address on record will be used as a default for the purposes of determining a current student’s physical location. The Registrar’s Office sends regular notifications to all students prior to census or the end of the third week of instruction in any given semester, reminding students to update their physical location data in GrizPortal (a web-based portal integrated with the UM SIS). The aforementioned default physical location will be used until such time that the University receives a student’s formal request to update their physical location address. Upon a student’s request to change their address, the new “physical location” address will be used as the default for determining the student’s physical location. 
2. State Authorization and Reciprocity Agreement (SARA): UM will determine the location of students for the purposes of reporting the number of distance education enrollments and out-of-state learning placements (OOSLP) to the National Council for State Authorization Reciprocity Agreements (NC-SARA). No identifying information of the student is reported to NC-SARA other than the student’s physical location.  
   1. Distance Education Enrollments: The physical location of students will be reported to NC-SARA for students who are enrolled exclusively in distance education courses. The Registrar’s Office sends regular notifications to all students prior to census or the end of the third week of instruction each semester. This notification reminds students to update their physical location data in GrizPortal if it changes at any time during the semester. 
   2. Out-of-State Learning Placements: The physical location of students participating in OOSLPs will be reported to NC-SARA. The Experiential Learning and Career Success (ELCS) office at UM is responsible for collecting this information. OOSLPs are tracked through a digital platform used to facilitate internships and other experiential learning activities by units on campus. ELCS works on an individual basis to collect OOSLP information for units that have opted out of using the digital platform. 

The procedure for the 91´ÎÔª (UM)’s student identity verification policy for distance education shall be executed by a cross-sector work group chaired by the Director of Institutional Compliance and composed of the Accreditation Liaison Officer (ALO) and representatives from The Office of Educational Initiatives and Innovation (EII), Information Technology (IT), Admissions, the Registrar’s Office, Financial Aid, Housing, and Enterprise Risk Management. This procedure fits within the broader context of the UM Student Code of Conduct (SCC), Article V, A, which prohibits acts of dishonesty such as falsification, unauthorized access, and false information and EII’s guidance on regular and substantive interactions in distance education courses and programs. 

The work group will bear responsibility for: 

• Ensuring the student who registers in a distance education course or program is the same student who participates in the course and receives credit. 
• Ensuring student privacy is protected. 
• Notifying students at the time of registration of any additional charges associated with verification procedures. 

The work group meets regularly to monitor University compliance with student identity verification requirements and will consider questions such as: 

1. How do we currently verify student identity? Are there new technical options for verifying identity that are in use or can/will be used as UM is adopting or has adopted new technology? 
2. Are we using online proctored examinations or online distance student meetings with faculty that include ways to identify who is participating? If so, how do we ensure privacy - for example meetings are one on one with faculty not as a whole group when showing ID. 
3. Are there any new ways privacy is being protected at UM? 
4. Is any new fee required related to verification? 
5. How do we communicate this policy to distance students and faculty? 
6. Does anything we have discussed require a change to current policy and procedure? 

Work group members determine whether University action is needed to ensure compliance with the student identity verification policy for distance education as well as with 34 CFR 600.02, 34 CFR 602.17, and the NWCCU policy on distance education. The work group is responsible for ensuring any needed actions are implemented and may adjust the set of questions regularly considered based on how UM’s methods to ensure compliance with these policies evolving over time. The group documents its work, especially changes and modifications, which are kept in UM’s institutional compliance files.

The 91´ÎÔª follows the .

Procedure Number: 201.70

Date Adopted: 2/14/08

Last Revision: 2/14/08, 2/17/22

Approved by: Faculty Senate

The 91´ÎÔª strives to align its principles of quality for online courses with the Office of the Commissioner of Higher Educations’ .

Policy: Regular and Substantive Interaction

Date Adopted: 8/25/25

Responsible Office(s): Office of Educational Initiatives and Innovation, Office of the Provost

Download a copy of the Regular and Substantive Interaction Policy