State Authorization: The Importance of Being Earnest

Internships, externships, field experiences, clinicals, rotations, clerkship, practicum, student teaching, and so on. Whatever the name, supervised field experience plays a large role in state authorization. In fact, a supervised field experience can trigger a physical presence in the vast majority of states. To remain in compliance, we must be able to pinpoint not only where our online students are but also where students are conducting their supervised field experiences. This includes both online and face-to-face students.

As indicated in a past article, UMKC was accepted as a participating SARA (State Authorization Reciprocity Agreement) institution on June 30, 2016. This eased the physical presence conundrum somewhat by reducing the institution’s regulatory burden. UMKC is currently able to offer some or all of its online programs in 48 states plus the District of Columbia. The number of states where UMKC can allow students to participate in supervised field experiences is slightly less—43.

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.

The mantra of state authorization is “It depends” because each state is different. Some states, while a SARA state, still require each university to register with their Secretary of State office. UMKC is currently waiting on a few states to respond to our inquiry. There are also a few states that are not members of SARA yet and the application process and corresponding fees apply.

Some stipulations exist regarding internships and SARA. For example, the Boards of Nursing in each state have separate rules and regulations regarding distance education as a whole. In addition to obtaining the general authorization for the university, a university must also obtain authorization from each state’s Board of Nursing before accepting and enrolling students from that state. Participation in SARA does not include authorization from the Board of Nursing.

With SARA, the rule of thumb for supervised field experiences is no more than 10 students, per location per academic program at one time. This means, for example, that we can have 10 students from the radiology program as well as 10 students from the anesthesiology program, both conducting their supervised field experience at KU Med. If there are more than 10 students from one program at one location, then the state authorization coordinator must seek approval from the host state SARA portal entity.

If you have questions, please contact Brandie Elliott, State Authorization Coordinator. The State Authorization map on the UMKC Online web site is kept updated with the states and district where UMKC is able to accept and enroll distance education students.