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State Authorization

State Authorization Compliance

Federal and state regulations [PDF] require that all institutions of higher education comply with existing state laws regarding distance learning. As these regulations are continuously evolving, Drexel University makes every effort to secure and maintain compliance. Drexel University works with regulatory agencies in each state and U.S. Territory to seek authorization, exemption or permission to offer distance education programs, courses and certificate programs to residents who wish to enroll in our distance learning education programs.

State Authorization Reciprocity Agreement (SARA)

The State Authorization Reciprocity Agreement (SARA) establishes a state-level reciprocity process that supports national efforts to increase the educational attainment by making state authorization of postsecondary institutions more efficient, effective, and uniform in regard to necessary and reasonable standards of practice across states; more effective in dealing with quality and integrity issues; and less costly for states and institutions and, thereby, the students they serve. For comprehensive information on SARA, please visit the website of the National Council for State Authorization Reciprocity Agreements (NC-SARA), the national organization responsible for coordinating the efforts of the four regional education compacts. Please see:

SARA | Essential Principles

  • Voluntary for states and institutions
  • National Council for SARA and four regional higher education compacts (MHEC, NEBHE, SREB, WICHE)
  • Requires states to approve their in-state institutions for SARA participation (based upon institutional accreditation and financial stability) and resolve student complaints
  • SARA states agree to impose no additional (non-SARA) requirements on institutions from other SARA states
  • Open to degree-granting postsecondary institutions from all sectors: public colleges and universities; independent institutions, both non-profit and for-profit
  • Uniform set of triggers of “physical presence”
  • Preserves state approval and oversight of on-the-ground campuses.
  • Shifts principal oversight responsibilities from the state in which the distance education is being received to the “home state” of the institution offering the instruction

SARA | What it does not address

  • Professional licensing board approval for programs leading to licensing: nursing, teacher education, psychology, etc.
  • Online offerings provided free and beyond the scope of current regulation of the degree programs of accredited academic institutions (free, non-credit MOOCs, etc.)
  • Non-credit instruction

SARA | Physical Presence Triggers

For purposes of SARA, an institution has physical presence and therefore must meet the state’s current non-SARA requirements if it does any of these things in a state:

  1. Establishes a physical location for students to receive synchronous or asynchronous instruction;
  2. Requires students to physically meet in a location for instructional purposes more than twice per full-term (quarter or semester) course for a total of more than six hours;
  3. Establishes an administrative office;
  4. Provides information to students for the purpose of enrolling students, or provides student support services, from a physical site operated by or on behalf of the institution in the state;
  5. Offers a “short course” that requires more than 20 contact hours in one six-month period;
  6. Provides office space to instructional or non-instructional staff;
  7. Maintains a mailing address or phone exchange in a state.
  8. Carries out field study or field research located at a field station, research station or other physical site at which a faculty member or other institutional employee or contractor supervises or otherwise directs two or more students in an activity exceeding the allowable short course length set forth in Subsection 5.4 and which either bears academic credit or is a requirement for a course or program.

Please see SARA Manual, Version 16.3, December 2016

SARA | NO Physical Presence Triggers

An institution does not have physical presence, and is therefore covered by SARA in SARA member states, if it is only:

  1. Offering courses to individuals via distance education in ways that do not require students to gather physically in groups, excepting the special provisions in Section 5;
  2. Advertising to students whether through print, billboard, direct mail, internet, radio, television or other medium;
  3. Offering distance education courses on a military base or vessel if enrollment in such courses is limited to active and reserve military personnel, their dependents, and civilian employees of the installation;
  4. Maintaining a server, router or similar electronic service device housed in a facility that otherwise would not constitute physical presence (the presence of a server or similar pass-through switching device does not by itself constitute the offering of a course or program in that state);
  5. Having faculty, adjunct faculty, mentors, tutors, recruiters or other academic personnel residing in a member state and working from their homes or another private, non-institutional site, provided that such staff is not engaged in activities that would otherwise constitute physical presence as defined by these Policies and Standards;
  6. Holding proctored exams on behalf of the institution in the host state;
  7. Having contractual arrangements in the home or host state, e.g. procurement contracts or course offerings through consortium agreements;
  8. Operating limited supervised field experiences (See subsection 5.13);
  9. Using recruiters in a SARA member state. This provision is not restricted to recruiting for courses or programs offered under SARA, and does include athletic recruiting.
  10. Engaging in field trips to visit existing sites or facilities for academic purposes not involving the establishment of residential or instructional facilities.

Please see SARA Manual, Version 16.3, December 2016

Drexel University | SARA Institution

Drexel University has been approved by Pennsylvania to participate in the National Council for State Authorization Reciprocity Agreements. NC-SARA is a voluntary, regional approach to state oversight of postsecondary distance education. Institutions that are members of SARA are authorized to provide online education to students from all SARA member states. States and institutions that choose to become members of SARA operate under a set of policies and standards overseen by NC-SARA and administered by four regional higher education compacts. For more information about the SARA initiative and the progress of state and institutional membership, please visit:

SARA Member States Currently authorized SARA member states include those noted on this map, which is maintained by NC-SARA.

Approval Timeline

  • On October 27, 2016, the Southern Regional Education Board (SREB) approved the Commonwealth of Pennsylvania to join SARA.
  • On December 2, 2016 the application from Drexel University to participate in the State Authorization Reciprocity Agreement (SARA) has been approved by the Pennsylvania Department of Education (PDE).
  • On December 22, 2016 the National Council for State Authorization Reciprocity Agreements (NC-SARA) approved our institutional participation. As a result, Drexel University is now permitted to participate in the National Council for State Authorization Reciprocity Agreements (NC-SARA).

Drexel University Information

Important Notes

Student Location

Educational activity under SARA is deemed to occur where the student is physically located at the time the student is in contact with the educational provider or a contractor acting on behalf of the provider. The student’s legal state of residence is not a factor in determining physical location for purposes of SARA.

Professional Licensure in States Outside of Pennsylvania

SARA has no effect on state professional licensing requirements. Academic programs and individual graduates must meet the standards required by that state’s applicable licensing agency, in order for a graduate to be eligible for a license. If you are considering one of our online nursing programs that leads to a professional license, please contact us at for information regarding our status in your state. You may also contact the appropriate licensing board in the state where you plan to receive instruction before beginning your academic program. Please see National Council of State Boards of Nursing for state-by-state listings.