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Into the Weeds of SARA Physical Presence Changing Role of States Implications for Institutions

Into the Weeds of SARA Physical Presence Changing Role of States Implications for Institutions. Bruce Chaloux SAN Meeting October 31, 2012. Three Keys to SARA Model. A more common sense approach to physical presence--redefines physical presence ‘triggers ’

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Into the Weeds of SARA Physical Presence Changing Role of States Implications for Institutions

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  1. Into the Weeds of SARAPhysical PresenceChanging Role of StatesImplications for Institutions Bruce Chaloux SAN Meeting October 31, 2012

  2. Three Keys to SARA Model • A more common sense approach to physical presence--redefines physical presence ‘triggers’ • Alters state roles and responsibilities • Creates a fee structure that is fair to institutions and states

  3. Physical Presence Triggers • What you can’t do (and be covered under SARA)… • Establish a physical location for students to receive synchronous or asynchronous instruction; for purposes of enrolling students, providing information to students about the institution, or providing student support services; • Provide office space to instructional or non-instructional staff; or • Maintaining a mailing address or phone exchange. • Requiring students to physically meet in a location for instructional purposes more than once during the course term

  4. “Physical Presence” • interstate supervised field experiences originating from campus-based programs in a member state are considered to be distance education (covered under SARA)if they have: • fewer than five students from each campus-based program in a member state physically present simultaneously at a single facility or site in a host state, and • do not involve any multi-year contract between a sending institution and a field site. Such programs are treated as distance education for purposes of determining whether they are covered by the provisions of SARA.

  5. What You Can Do Under SARA (What doesn’t trigger Physical Presence) • Offering courses via distance education. • Advertising to students whether through print, billboard, direct mail, internet, radio, television or other medium; • Student field experiences. Offering educational field experiences for students. • An educational field trip arranged for a group of students that are normally in residence at an institution in another state; • Face-to-face non-credit courses that are not a part of a degree or non-degree program that are less than 16 clock hours in length.

  6. What Doesn’t Trigger Physical Presence • Serving military personnel • Maintaining a server, router or similar electronic service device housed in a facility that otherwise would not constitute physical presence; • Having faculty, adjunct faculty, mentors, tutors, or other academic personnel residing in a member state; • Proctored exams at or by the institution; • Contractual arrangements in the home or host state.

  7. Changing State Roles…Implications for Institutions (for SARA States) • Home State/Host State Model • “Drivers License” approach--‘Approval’ from home state recognized in other states • State procedures will need to be established • Designation of an agency, or agencies, to conduct reviews • States with no current authorization processes in place

  8. Benefits/Issues for States • Reduce costs • Benefit home state institutions • Simplify existing relationships • Require legislation • Changes existing state approach • Adoption/approval of SARA • Politics (forces for and against)—’turf’ • Which states will join • Will ‘easy’ states become more regulatory?

  9. Cost Considerations • Still under development but… • With a threshold number of states joining SARA • Significant reduction in fees for institutions with a national ‘footprint’ • No fees if an affiliated state (but institutions will have current fees for operating in non-home state) • Annual fee to home state for institutions • Initial estimate: $1,500 - $5,000 / year. • Adjusted over time as more join • Significant savings to institutions in staff and legal costs over the current model

  10. Some Closing Thoughts/Questions • What’s in it for you? • A simpler, more cost-effective and less time-consuming process—deal with one state (your own) and not each state individually • Should you support these efforts? If so, how? • What happens if this does not reach a critical mass of states? • Can this really work? • Your questions/comments…

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