Institutions offering online or hybrid degrees have to research and file with State authorities. It is a very time consuming and manpower-taxing initiative for any institution to tackle.


This ‘registration’ stems from a 2010 regulation issues by the U.S. Department of Education that tied an institution’s ability to offer federal financial aid in a State to the institution being authorized in the student’s State. This regulation was canceled, or ‘vacated’, later by a federal course ruling and it is currently NOT being enforced. However, regardless of the status of this federal regulation, States are still expecting higher education institutions, like ours, to follow the laws and regulations put out by the State. Here are a few resources offered through WCET (Western Interstate Commission for Higher Education).

Need to Know

  • Each State has their own requirements for higher education institutions, that may or may not be like the requirements of other States.
    • These requirements may be different depending on the requirements for each online or hybrid program.
    • Some States are charging fees for registration, while others are only requesting letters of intent.
  • There are regional compacts, that cost each State to join and a yearly fee. Each State needs to assemble a group to task with the administrative duties of joining a compact.
    • There is a ‘mother compact to rule them all’ called SARA.
    • “The four regional compacts (MHEC, NEBHE, SREB and WICHE) are each developing their implementation models for SARA: M-SARA, N-SARA, S-SARA and W-SARA. Those documents are at varying stages of consideration in the four regions. Later this year, the National Council for State Authorization Reciprocity Agreements will review the four regional documents for consistency with provisions of the report of the national Commission on Regulation of Postsecondary Distance Education.” (1)

Area for Discussion

As far as I can tell, a Jesuit body of some kind to assist in this effort is not currently being discussed. I can’t help but think there is a strong need for such a body. This effort is new and extremely time-consuming for every institution. The small and medium-sized institutions in our  group are at a severe disadvantage. 

What would such a body do, exactly? I can picture a member from each institution participating in this body, perhaps right here in this blog post. Each member would contribute to the compiled list of steps and resources for State Reciprocity. Once we have a nice collection of resources, I could then compile a ‘guide’ for individuals in positions like mine who have to apply for State reciprocity.

Why participate? As I mentioned, this effort is new and extremely time-consuming. To me, it doesn’t make sense for every institution (especially ones like my own, where one person is really charged with this task) to have to ‘discover’ and ‘uncover’ the steps and resources needed. We can accomplish more and work more effectively by working together.

Questions for Fellow Jesuit Colleagues

  • Can you add to any of the info here?
  • Are there areas of collaboration for the Jesuit network?
  • Is there anything you can share with your Jesuit colleagues?