Federal Regulation and State Authorization

The US Department of Education (USDOE) sets the Code of Federal Regulations for higher education institutions offering distance education courses and programs. There are particular regulations applied to credit-bearing courses and activities that are required for program completion. The USDOE also requires academic programs to make informational disclosures to enrolled or prospective students in program areas that lead to professional licensures required to practice in a profession.

Each state sets their own guidelines for institutions offering learning activities within that state’s borders. Where University of Minnesota students are taking classes from a location outside the state of Minnesota or being placed in a state outside of Minnesota for certain activities such as clinical practica, student teaching, internships, or various other field experiences required for degree completion, the University is required to obtain authorization to conduct business in that state. States may also require the University to obtain approval for regulated activities like faculty teaching from another state, marketing, advertising, and more.

The University of Minnesota is a member of the National Council of State Authorization Reciprocity Agreements (NC-SARA). NC-SARA sets rules for its members that allow institutions to operate any state that is part of NC-SARA, under certain parameters, without seeking additional permissions. Most states, US territories, and the District of Columbia are NC-SARA members.

Regulatory reporting and disclosure requirements

Under the Code of Federal Regulations, academic programs are required to complete the following compliance steps:

  • Report student placements in learning activities outside the institution's home state
  • Make public disclosures regarding education requirements for professional licensure
  • Make accessible the student complaint process of their respective programs and campuses
  • Make individual disclosures regarding education requirements for professional licensure (done through MyU)

Activities not covered by NC-SARA

The following activities are not covered by SARA. Please inform Senenge Andzenge if your unit:

  • Sends more than 10 students to the same location in another state for internships, student teaching, practica, or other field experiences
  • Requires an online student to take a proctored exam outside of Minnesota,
  • Offers short-term academic credit seminars in other states,
  • Employs an online instructor who lives in another state,
  • Employs an on-the-ground recruiter in another state, and/or
  • Establishes a physical office or mailing address in another state.
  • Almost all states have additional requirements for professional programs leading to licensure (i.e., nursing, education). It is the responsibility of the individual college or program to make sure these requirements are met.
  • All of the University of Minnesota's online and hybrid programs should be listed on the University of Minnesota Online website. If your college offers an online or hybrid program that is not listed, please complete this program update form.