Brandie Elliott / University of Missouri-Kansas City

Internships, externships, field experiences, clinicals, rotations, clerkship, practicum, student teaching, and so on. Regardless of the name, supervised field experiences play a large role in state authorization. In fact, a supervised field experience alone can trigger a physical presence in the vast majority of states. This includes both online and students enrolled in face-to-face programs.
If an institution is participating in NC-SARA (National Council for State Authorization Reciprocity Agreements), the rule is fairly simple: 10 students per location per program at one time. SARA applies solely to distance education activity conducted across state lines. It does not apply to distance education activity inside a state or to on-ground campuses.
To be clear, the SARA definition of “supervised field experience” is as follows:
“Supervised field experience” means: a student learning experience comprised primarily of the practical application of previously studied theories and skills, under the oversight of a supervisor, mentor, faculty member or other qualified professional, located in the host state, who has a direct or indirect reporting responsibility to the institution where the student is enrolled whether or not credit is granted. The supervised field experience is part of a program of study offered by enrolling SARA institution. Examples include practica, student teaching, or internships. Independent off-campus study by individual students not engaged in supervised field experience is exempt from requirements of SARA and does not constitute a physical presence of a postsecondary institution in a SARA member state.
If there are more than 10 students in a particular program (for example, 11 students in the radiology program at one hospital), then you must obtain prior approval from the state SARA portal agency. Each state differs. One state may grant you approval whereas another state will draw the line at 10, no more. In that case, a university must obtain authorization in that particular state.
The Rule of 10 does not sidestep the professional licensing requirements. An institution must still obtain approval from the necessary licensure boards prior to allowing a student to conduct their supervised field experience in a certain state, as well as enroll in an online degree program.
If a university is not participating in SARA, then it is business as usual: obtaining authorization prior to any activity that would trigger a physical presence.