Managing the State Authorization Process:Strategies for Success

Stefanie Pfister and Christina M. SaxOffice of Professional, Continuing, and Distance Education

Shippensburg University

Originally prepared for Instructional Technology Council Webinar – Dec, 2014Updated – Dec, 2015

• Focus of this presentation

• Overarching strategies to manage state authorization

• Nuts and bolts of managing state authorization

• Contact information

Outline

• State Authorization: Title 34 – CFR 600.9

• Focus IS: Set of strategies and best practices for managing the state authorization requirements and processes

• Focus is NOT: An update on state and federal state authorization requirements, legislation, and trends• WCET websites:

• http://wcet.wiche.edu/advance/state-authorization-network

• http://wcet.wiche.edu/learn/issues/state-authorization

Focus of this Presentation

Overarching Strategies to Manage State Authorization

1. Engage senior leadershipa. Garner initial & ongoing support

b. Ensure an understanding of the requirements and implications

c. Foster strategic and compliance perspectives

d. Demonstrate amount of time and effort involved

2. Before diving in to fill out application forms …a. Understand institutional culture and distance education profile

b. Decide what unit is responsible for doing the work

c. Prioritize - develop a strategy, approach, and action plan

d. Understand that it’s more than just distance education

Overarching Strategies – 1

3. Commit dedicated state authorization staff and/or liaison

4. Involve several different people & units from across the institution

5. Establish new processes, routines, policies, reports, and relationships

6. Establish ongoing education & communication channels

7. Be flexible, adaptable, and ready to change course – the sands are ever shifting, both externally & internally

8. Be diligent and persistent

9. Don’t bite off more work than you can chew

10. Find a good balance: good faith efforts and moving steadily toward compliance

Overarching Strategies – 2

Nuts and Bolts of Managing State Authorization

• Recognize that authorization can require A LOT of work and don’t try to do it all at once.

• What aspects and states require top priority based on your institution’s offerings? Consider …• States in which your institution has the biggest footprint – greatest

volume of online classes/programs & f2f presence of students

• Other physical presence triggers – advertising/marketing, recruiting, residence of DE faculty/staff, location of servers

• Low hanging fruit – states in which you will be exempt and in which application process is relatively simple

• Programs that entail external licensure/certification involve additional requirements and costs to additional state licensing agencies

• Calculate costs and cost/benefit analysis for each state – consider application time, cost, return on investment based on enrollments

Prioritize & Focus

Example phased-in strategy to obtain initial approvals for an institution with more online enrollments that f2f placements in another state might be:

• First tier states: • from which majority of out of state students originate• exempt from requiring approvals (obtain documentation)• easy and/or inexpensive registration/approval process• other states in incoming admissions group

• Second tier states:• from which additional current out of state students originate• complicated and/or costly application process

• Third tier states:• very difficult and/or costly application process• from which no enrolled students originate

Phased-In Example Strategy

• Assign and train dedicated state authorization staff and office

• Decide upon your criteria for tracking & reporting students

• Build custom reports to gather baseline data on a routine and ongoing basis• From Student Information System

• Obtain access to run reports rather than relying on another office

• Introduce issues, educate all affected groups, provide ongoing updates, cultivate supporters. For example:• Annually: Executive Management Team & President’s Cabinet

• Quarterly: Provost, Deans, DE Committee, Faculty

• Weekly-Monthly: Frontline offices and individuals

Put the Pieces in Place

• Overall institutional data• Number & residency of all students• Number & residency of students in online courses and programs• Number & location of f2f & blended courses and instructional

experiences occurring outside PA• Student teaching, internships, field placements, practica - what state,

how many students, site information

• Admissions• Schedule of recruiting events• Track admissions offers, acceptances, confirmations

• Marketing/Communications• Current & future plans - methods and locations

• Human Resources• Residency of faculty/staff involved in supporting DE

Gather Baseline Data Every Semester

• Bursar/Student Accounts• How does refund policy compare to those specified by other states? How will

your institution comply with the tuition refund policies of other states?

• Financial aid• Refund policies; Title IV financial aid requirements & reporting

• Accounting• Current financial statement & audit report• Issuing application checks

• Institutional Research• Official & consistent institutional data: IPEDS, Carnegie classification, other

historical data

• Legal counsel, state system office, own state department of education• Items that are problematic/prohibited by your regs/laws (e.g. surety bond)

• Provost & President• Signatures on affidavits and applications

• Institutional accreditation liaison• Compliance, reporting requirements & needs

Additional Partners, Information, Considerations

• What information is needed for an application? It Depends!

• States vary in the method and content of their applications:• Simple webform

• Simple paper form

• Paper form with supporting documents

• Binders of documents

Plan Ahead & Be Prepared – Applications Vary

Create & Maintain State Authorization Website

Other Website Approaches• University of Delaware

http://www.pcs.udel.edu/udonline/state-authorization/index.html

• Northwestern State University of Louisianahttp://compliance.nsula.edu/

• University of Floridahttp://www.distance.ufl.edu/state-authorization

Shippensburg University Example www.ship.edu/PCDE/Online/stateauth/

Programs that involve external licensure/certification Tell students … “Check your home states’ licensure/certification requirements, to be sure that this program makes you eligible and/or prepares you for licensure/certification in your home state.”

Complaint Website – Required by HR668.43(b)

• Access to your institution’s state approval & licensing agency

• Access to your institution’s regional accreditor

• Higher education complaint entities in other states

• Example: www.ship.edu/PCDE/Online/Complaint_Process/

Online Education Complaint Form – Additional Best Practice

• Reminder of your institution’s complaint/appeal processes

• Easy path to submit a compliant/appeal to your institution

• Example: www.ship.edu/pcde/online/online_education_complaint_form/

Create & Maintain Complaint Website

Sample Complaint Website & Form

• Document everything and establish an organization scheme

• Adopt technology tools to manage the process (i.e. project management software, databases, etc.)

• Take into account:• Adding new states to your authorization list• Adding new programs/activities – update status with states• Renewals of existing authorizations

• Adapt to changes in state and federal laws & regulations• Including the progress of State Authorization Reciprocity

Agreement (SARA)

• Provide ongoing updates to all university stakeholders

Develop an Annual Workflow

Jan

Feb

Mar

• Develop your own informal state authorization network• Identify individuals like you, at institutions like yours, with online

and out-of-state f2f courses, programs, and activities similar to those of your institution

• Talk to each other regularly

• Share approaches, strategies, updates, templates, questions, problems and solutions, information gained from contact with regulators and conferences

• Consult each other’s websites

• Connect with states’ higher education agency/office

Make Personal Connections

• Sign-up for listservs & join organizations that routinely distribute updates and information• WCET, SAN, NC-SARA, your state’s regional compact (MHEC, NEBHE,

SREB, WICHE)

• Stay abreast of trends at the state and federal level• Inside HigherEd, Chronicle of Higher Education• Accreditors’ newsletters• USDOE – negotiated rule making, Dear Colleague letters• USDOE info flow to your institution – President, Provost, financial aid

officer• State Higher Education Executive Officers Association website (SHEEO)

• Participate in webinars, face-to-face workshops, conferences

Stay Informed on an Ongoing Basis

Contact Information

Stefanie Pfister, M.P.A.Compliance and Training Coordinator

Shippensburg University

Email: smpfister@ship.edu

Phone: 717-477-1502

Christina M. Sax, Ph.D.Associate Provost and Dean of Academic Outreach &

Innovation

Shippensburg University

Email: csax@ship.edu

Phone: 717-477-1348

Twitter: @CMSax

Contact Information