New study finds limited staff capacity at state agencies may hinder effective implementation of distance learning agreements, offers policy recommendations

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February 6, 2024

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New study finds limited staff capacity at state agencies may hinder effective implementation of distance learning agreements, offers policy recommendations

States participating in the State Authorization Reciprocity Agreement (SARA) must increase staff capacity to administer that agreement and should also be permitted to enforce their own student protection policies, according to a new study from the Postsecondary Equity & Economics Research (PEER) Project. 

The study, authored by Rebecca S. Natow of Hofstra University, examines the experiences of state agencies with implementing SARA. Under the Higher Education Act, all colleges must be legally authorized by a state to be eligible to participate in federal financial aid programs in that state. However, the Department of Education's regulations permit schools that enroll out-of-state online students to satisfy this requirement without gaining approval in each online student’s state by joining a reciprocity agreement. SARA is currently the only state authorization reciprocity agreement. 20 state agencies participated in Dr. Natow’s study about SARA.

While respondents expressed overall satisfaction with SARA and the training, information, and working relationships they gain to implement the agreement, the lack of dedicated staff has resulted in state agency employees being given SARA responsibilities in addition to their already-assigned job duties. This additional use of staff time was frequently mentioned as the primary “opportunity cost” of joining SARA, alongside administrative costs, loss of revenues, and not being able to enforce higher education-specific consumer protection laws, ultimately impeding state agencies’ ability to protect students. 

The study also raised questions around the student complaint process required under SARA, which requires students to exhaust their institutions’ complaint process before submitting their complaints to the state agency that authorizes their schools. The study found that SARA-participating states rarely receive complaints from online students. 

“Evidence from the present study shows that limited staff capacity remains problematic,” the report finds. “For state authorization reciprocity to be implemented efficiently, and to guard against disruptions to consumer protection that would result should a staff member doing all or most SARA administration leave the agency, states should increase funding and personnel for these agencies.”

Based on findings from the survey, Dr. Natow recommends the following policy recommendations:

• States should build capacity for SARA implementation by providing additional staff to administer the agreement.

• States should be permitted to enforce their own higher education-specific consumer protection policies, should any exist beyond the authorization process.

• SARA should provide for students’ home states to play a more active role in resolving complaints that reach the state level.

• To encourage students to pursue unresolved complaints at the state level, information should be provided to them about the process for appealing a complaint through the state.

A full copy of the study can be found on the PEER Project website.