National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA

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National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
National Council for State Authorization
               Reciprocity Agreements
               NC-SARA Board Meeting
               Virtual Meeting

                May 4-5, 2021

3005 Center Green Drive Suite 130 ● Boulder, CO 80301 ●
           303.848.3764 ● www.nc-sara.org
                   Page 1 of 34
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
Table of Contents
AGENDA ....................................................................................................................................... 2
NC-SARA Board Members ........................................................................................................... 3
NC-SARA Staff ............................................................................................................................. .7
Regional Compact Staff–SARA Directors And Coordinators ..................................................... .8
NC-SARA Consultants and Guests............................................................................................... 9
Agenda Item I: Approval of Minutes of the October 28-29, 2020 Meeting .............................. 11
Agenda Item II: Update on NC-SARA Progress ........................................................................ 24
Agenda Item III: Update from Regional Compacts on SARA ................................................... 25
Agenda Item IV (ACTION): Report and recommendations for the Executive Committee....... 26
Agenda Item V (ACTION): Finance Committee report ............................................................. 27
Agenda Item VI (ACTION): Federal Higher Education Landscape Impact on NC-SARA ......... 28
Agenda Item VII: Update on 21st Century Distance Education Guidelines .............................. 29
Agenda Item VIII: Branch Campus Working Group ................................................................. 30
Agenda Item IX (ACTION): Modifications to the SARA Policy Manual ...................................... 31
Agenda Item VII (ACTION): Executive session ......................................................................... 49
Agenda Item VIII (ACTION): Questions, comments, reflections from board members .......... 49
Appendix A: Staff Meetings and Presentations ....................................................................... 50
Appendix B: Report from the NC-SARA Branch Campus Working Group to the NC-SARA
Board …………………………………………………………………………………………………………………..55
Appendix C: Proposed 21st Century Distance Education Guidelines……………………………….83

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                   National Council for State Authorization Reciprocity Agreements (NC-SARA)
                               NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
AGENDA

Welcome and introductions – Teresa Lubbers, Chair

Agenda Item I (ACTION): Approval of minutes of the October 27-29, 2020 meeting

Agenda Item II: Update on NC-SARA progress – Lori Williams and staff

Agenda Item III: Update from Regional Compacts on SARA

   a) Susan Heegaard, Midwestern Higher Education Compact (MHEC)
   b) Michael Thomas, New England Board of Higher Education (NEBHE)
   c) Stephen Pruitt, Southern Regional Education Board (SREB)
   d) Demarée Michelau, Western Interstate Commission for Higher Education
      (WICHE)

Agenda Item IV (ACTION): Report and recommendations of the Executive Committee –
Teresa Lubbers, Chair

Agenda Item V: (ACTION): Finance Committee Report – Leroy Wade, Treasurer

Agenda Item VI: Federal Higher Education Landscape Impact on NC-SARA – Catherine
Guttman-McCabe

Agenda Item VII: Update on 21st Century Distance Education Guidelines – Sally Johnstone
& Barbara Brittingham

Agenda Item VIII: Branch Campus Working Group – Belle Wheelan & Susan Heegaard

Agenda Item IX: (ACTION): Modifications to the SARA Policy Manual

Agenda Item X (ACTION): Executive session

Agenda Item XI: Questions, comments, reflections from Board members

Adjourn

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                   National Council for State Authorization Reciprocity Agreements (NC-SARA)
                               NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
NC-SARA Board Members

Please note that the current term for each Board member ends after the final board
meeting of the specified year next to each name. Compact presidents are not term
limited.

 Rob Anderson – 2022                                Art Coleman – 2022
 President                                          Managing Partner and Cofounder
 State Higher Education Executive                   Education Counsel, LLC
 Officers Association                               101 Constitution Ave NW Suite 900
 3035 Center Green Drive Suite100                   Washington, DC 20001
 Boulder, CO 80301                                  202.689.2961
 303.541.1605                                       art.coleman@educationcounsel.com
 randerson@sheeo.org
                                                    Laurie Dodge – 2022
 Barbara Ballard – 2021                             Vice Chancellor of Institutional
 State Representative Kansas                        Assessment and Planning and Vice
 Legislature                                        Provost
 Dole Institute at the University of                Brandman University
 Kansas                                             16355 Laguna Canyon Road
 2350 Petefish Drive                                Irvine, CA 92618
 Lawrence, KS 66045                                 949.341.9813
 785.864.4900                                       ldodge@brandman.edu

 *Chris Bustamante – 2022                           Lanna Dueck – 2023
 Executive Director, Arizona Community              Executive Director
 College Coordinating Council                       Arizona SARA Council
 Rio Salado College                                 2323 W. 14th Street
 11617 South 71st Street                            Tempe, AZ 85284
 Tempe, AZ 85284                                    480.517.9229
 602.320.3297                                       ldueck.azsara@riosalado.edu
 bustamanterio1@gmail.com
                                                    *Susan G. Heegaard – Continuing
 John Cavanaugh – 2022                              President
 Former President and CEO (Retired)                 Midwestern Higher Education
 Consortium of Universities of the                  Compact Fifth Avenue South, Suite
 Washington Metropolitan Area                       450 Minneapolis, MN 55401
 291 Abercorn Circle                                612.677.2761
 Chapel Hill, NC 27516202.331.8080                  susanh@mhec.org
 globaljcc@gmail.com

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            National Council for State Authorization Reciprocity Agreements (NC-SARA)
                        NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
Angela Lee – 2023                                           Carlos Morales – 2023
Executive Director of the District of Columbia              President Tarrant County Colleges
Higher Education Licensure Commission                       Connect Campus
1050 First Street, NE,                                      444 N. Henderson Street
Washington, DC 20002                                        Ft. Worth, Texas 76102
202.412.4705                                                817.515.8002
angela.lee@dc.gov                                           carlos.morales@tccd.edu

*°Teresa Lubbers – 2021                                     *Stephen Pruitt – Continuing
Chair                                                       President
Commissioner                                                Southern Regional Education Board
Indiana Commission for Higher Education                     592 10th Street Northwest
101 West Ohio Street, Suite 300                             Atlanta, GA 30318
Indianapolis, IN 46204                                      404.875.9211
317.464.4400                                                stephen.pruitt@sreb.org
tlubbers@che.in.gov
                                                            Pamela “Pam” Quinn – 2022
°Leah K. Matthews – 2021                                    Vice President for Academic Affairs
Executive Director                                          (Interim) Tarrant County College-
Distance Education Accrediting Commission                   Connect Campus
1101 17th Street Northwest, Suite 808                       LeCroy Center
Washington, D.C. 20036                                      Dallas County Community College
202.234.5100, ext.101                                       District
leah.matthews@deac.org                                      1213 Chapel Hill Court
                                                            McKinney, TX 75069
°Demarée “Demi” Michelau – Continuing                       214.957.8750
President                                                   pamquinn@icloud.com
Western Interstate Commission for Higher
Education                                                   *Edward “Ed” Ray – 2021
3035 Center Green Drive, Suite 200                          Vice Chair
Boulder, CO 80301                                           President (Retired)
303.541.0121                                                Oregon State University Office of the
dmichelau@wiche.edu                                         President
                                                            600 Kerr Administrative Building
°Patricia “Pat” O’Brien – 2022                              Corvallis, OR 97331
Senior Vice President of the Commission                     541.737.4133
New England Commission of Higher Education                  ed.ray@oregonstate.edu
3 Burlington Woods, Suite 100
Burlington, MA 01803
781.425.7712
pobrien@neche.org
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                    National Council for State Authorization Reciprocity Agreements (NC-SARA)
                                NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
°George E. Ross – 2021                                  *Larry Tremblay – 2023
President Emeritus                                      Deputy Commissioner
Central Michigan University                             Planning Research and Academic
125 Somerset Hill                                       Affairs (Retired)
McDonough, GA 30253                                     Louisiana Board of Regents
989.854.6234                                            2221 Hood Avenue
ross14ge@cmich.edu                                      Baton Rouge, LA 70808
                                                        225.343.7684
Paul Shiffman – 2022                                    ltremb1948@gmail.com
Chief Executive Officer
Presidents’ Forum at Excelsior College                  *°Leroy Wade – 2022
(Retired)                                               Treasurer
201 Burwick Road                                        Deputy Commissioner
Highland Heights, OH 44143                              Missouri Department of Higher
440.683.1355                                            Education and Workforce
pshiffman@excelsior.edu                                 Development
                                                        P.O. Box 1469
Peter Smith – 2023                                      Jefferson City, MO 65102
Orkand Chair and Professor of Innovative                573.751.2361
Practices in Higher Education                           leroy.wade@dhewd.mo.gov
University of Maryland Global Campus
2022 Foothills Road                                     Belle Wheelan – 2021
Santa Fe, NM 87505                                      President
954.218.0184                                            Southern Association of Colleges
peter.smith@umuc.edu                                    and Schools Commission on
                                                        Colleges
Michael Thomas – Continuing                             1866 Southern Lane
President and Chief Executive Officer New               Decatur, GA 30033
England Board of Higher Education 45                    404.679.4512
Tempe Place                                             bwheelan@sacscoc.org
Boston, MA 02111
617.357.9620, ext. 119                                  *Member of the NC-SARA
mthomas@nebhe.org                                       Executive Committee
                                                        °Member of the NC-SARA Finance
                                                        Committee

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           National Council for State Authorization Reciprocity Agreements (NC-SARA)
                       NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
NC-SARA Staff

Staff Address:
National Council for State Authorization Reciprocity Agreements
3005 Center Green Drive, Suite 130
Boulder, CO 80301

Ray Audett                                           Holly Martinez
Associate Director for                               Accounting Technician and
Technical Operations                                 CustomerSupport Specialist
303.848.3278                                         303.848.3275
raudett@nc-sara.org                                  hmartinez@nc-sara.org

Marianne Boeke                                       Nick Ortiz
Senior Director for Research and State               Student and Institution Support
Support                                              Technical Specialist
303.242.5037                                         303.242.5036
mboeke@nc-sara.org                                   nortiz@nc-sara.org

Melanie Booth                                        Yovani Pina
Director for Educational Programs                    Director – Information Technology
and Communications                                   970.200.8409
720.684.5854                                         ypina@nc-sara.org
mbooth@nc-sara.org
                                                     Jessica Prihoda
Lauren Brunell                                       Administrative Assistant
Executive Assistant                                  303.848.3764
303.848.3764                                         jprihoda@nc-sara.org
lbrunell@nc-sara.org
                                                     Shannon Walker
Rachel Christeson                                    Associate Director for BusinessOperations
Assistant Director for Research                      Human Resources303.242.5038
and Data Analysis                                    swalker@nc-sara.org
720.600.2354
rchristeson@nc-sara.org                              Lori Williams
                                                     President and Chief Executive Officer
Mary Agnes Larson                                    303.848.3283
Executive Director for Student                       lwilliams@nc-sara.org
and Institution Support
303.848.3288                                         Jeannie Yockey-Fine
mlarson@nc-sara.org                                  General Counsel
                                                     303.647.5055
                                                     jyockey-fine@nc-sara.org

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                   National Council for State Authorization Reciprocity Agreements (NC-SARA)
                               NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
Regional Compact Staff–SARA Directors And Coordinators
Midwestern Higher Education Compact - MHEC                 Southern Regional Educational Board – SREB

Emily Jacobson                                             Wanda Barker
Manager, M-SARA                                            Director, S-SARA
Midwestern Higher Education Compact                        Division Director of Education Technologies
105 Fifth Avenue, Suite 450                                and Multi-State Cooperative Programs
Minneapolis, MN 55401                                      Southern Regional Education Board 592
612.677.2771                                               10th Street Northwest
emilyj@mhec.org                                            Atlanta, GA 30318
                                                           404.875.9211, ext.258
Leah Reinert                                               wanda.barker@sreb.org
Policy and Research Manager
Midwestern Higher Education Compact                        Elisa Jaden
105 Fifth Avenue, Suite 450                                Coordinator, S-SARA
Minneapolis, MN 55401                                      Student Access Programs and Services
612-677-2775                                               Southern Regional Education Board 592
leahr@mhec.org                                             10th Street Northwest
                                                           Atlanta, GA 30318
New England Board of Higher Education                      404.875.9211, ext. 217
– NEBHE                                                    elisa.jaden@sreb.org

Sheridan Miller                                            Western Interstate Commission for
Policy & Research Analyst/SARA Coordinator                 Higher Education – WICHE
New England Board of HigherEducation
45 Tempe Place                                             Shelley Pluto
Boston, MA 02111                                           Administrative Assistant III, W-SARA
617.533.5924                                               Western Interstate Commission for Higher
smiller@nebhe.org                                          Education
                                                           3035 Center Green Drive, Suite 200
Rachael Stachowiak                                         Boulder, CO 80301
Associate Director, N-SARA                                 303.541.0317
New England Board of HigherEducation                       splutto@wiche.edu
45 Tempe Place
Boston, MA 02111                                           Christina Sedney
617.533.9503                                               Director of Policy Initiatives and State
rstachowiak@nebhe.org                                      Authorization, W-SARA
                                                           Western Interstate Commission for Higher
                                                           Education
                                                           3035 Center Green Drive, Suite 200
                                                           Boulder, CO 80301
                                                           303.541.0238
                                                           csedney@wiche.edu

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           National Council for State Authorization Reciprocity Agreements (NC-SARA)
                       NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
NC-SARA Consultants and Guests

Alan Contreras
Consultant
3895 Kevington Avenue
Eugene, OR 97405
acontrer56@gmail.com

Catherine R. Guttman-McCabe
Partner
Potomac Law Group, PLLC
1300 Pennsylvania Avenue, NW, Suite 700
Washington, D.C. 20004
(202) 262-7083
cguttman-mccabe@potomaclaw.com

Barbara Brittingham
NCHEMS Consultant
3035 Center Green Dr
Suite 150
Boulder, CO 80303
(303) 497-0301
BBrittingham@neche.org

Sally Johnstone
NCHEMS Consultant
3035 Center Green Dr
Suite 150
Boulder, CO 80303
(303) 497-0301
sally@nchems.org

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                    National Council for State Authorization Reciprocity Agreements (NC-SARA)
                                NC-SARA Board Meeting | Virtual | May 4-5, 2021
National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
Welcome and introductions — Teresa Lubbers, Chair

Action Item:          ☐ Yes              ☒ No

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          National Council for State Authorization Reciprocity Agreements (NC-SARA)
                      NC-SARA Board Meeting | Virtual | May 4-5, 2021
NC-SARA AGENDA ITEM
Agenda Item I: Approval of Minutes of the October 28-29, 2020 Meeting

Action Item:   ☒ Yes           ☐ No

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                 National Council for State Authorization Reciprocity Agreements (NC-SARA)
                             NC-SARA Board Meeting | Virtual | May 4-5, 2021
MINUTES OF THE NC-SARA BOARD MEETING
October 28-29, 2020
VIRTUAL MEETING
DENVER, COLORADO
NOTICE OF MEETING

Notice of the time and place of the NC-SARA Board Meeting was posted on the NC-SARA website
and given to the Board members, regional compact SARA staff, and other interested parties.

An agenda is maintained in the NC-SARA office at 3005 Center Green Drive, Suite 130, Boulder,
Colorado, 80301 and online at www.nc-sara.org.

Welcome and introduction: Teresa Lubbers, Chair

Board members in attendance:

Rob Anderson                                                            Demarée Michelau
Barbara Ballard                                                         Stephen Pruitt
Chris Bustamante                                                        Pamela Quinn
John Cavanaugh                                                          Edward Ray
Art Coleman                                                             George Ross
Kathryn Dodge                                                           Paul Shiffman
Laurie Dodge                                                            Peter Smith
Dianne Harrison                                                         Michael Thomas
Susan Heegaard                                                          Larry Tremblay
Paul Lingenfelter                                                       Leroy Wade
Teresa Lubbers                                                          Belle Wheelan
Leah Matthews

NC-SARA staff present:
Raymond Audett                                                          Nick Ortiz
Marianne Boeke                                                          Richard Parker
Melanie Booth                                                           Jessica Prihoda
Lauren Brunell                                                          Shannon Walker
Rachel Christeson                                                       Lori Williams
Mary Larson                                                             Jeannie Yockey-Fine
Holly Martinez

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                    National Council for State Authorization Reciprocity Agreements (NC-SARA)
                                NC-SARA Board Meeting | Virtual | May 4-5, 2021
Regional Compact Staff:

Wanda Barker, SREB
Emily Jacobson, MHEC
Elisa Jaden, SREB
Sheridan Miller, NEBHE
Shelley Plutto, WICHE
Christina Sedney, WICHE
Rachael Stachowiak, NEBHE

Guests:

Alan Contreras
Michael “Mike” Goldstein
Catherine R. Guttman-McCabe

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                   National Council for State Authorization Reciprocity Agreements (NC-SARA)
                               NC-SARA Board Meeting | Virtual | May 4-5, 2021
MINUTES OF THE NC-SARA BOARD MEETING

Meeting was called to order at 9:00 AM (Mountain Standard Time)

OCTOBER 28, 2020

Chair Lubbers opened the meeting with a welcome to all and roll call. All board members
reported as present.

Agenda Item I (ACTION): Approval of minutes of the May 6, 2019 meeting

              Motion to approve – Ed Ray
              Seconded – John Cavanaugh

              Following a friendly amendment from Michael Thomas to correct the minutes to show
              Rachael Stachowiak works for NEBHE and not WICHE, the approval passed
              unanimously.

Agenda Item II: Update on NC-SARA Progress

    a)    Lori Williams, NC-SARA
          NC-SARA President and Chief Executive Officer Lori Williams shared an updateon
          the progress made in the first quarter of NC-SARA’s first three-year strategic plan,
          with assistance from General Counsel Jeannie Yockey-Fine and Executive Director
          for Student and Institution Support, Mary Larson. Jeannie Yockey-Fine shared about
          the status of the annual data collection and report, citing a 99% response rate,
          during the pandemic, with over 3 million distance education enrollments and nearly
          350,000 out of state learning placements.

Assistant Director for Research and Data Analysis, Rachel Christeson gave an update on the
status of the enrollment and experiential learning placement reporting for 2019, as well as an
update on the status of the cost savings study.

Jeannie Yockey-Fine gave a brief update regarding federal regulations impacting NC-SARA.

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                   National Council for State Authorization Reciprocity Agreements (NC-SARA)
                               NC-SARA Board Meeting | Virtual | May 4-5, 2021
President Williams shared a few updates and graphic images representing the value of NC-SARA
and the improvements to consumer protection, and continuedwith some updates on the progress
made on achievement of the goals and objectives in the strategic plan in its first quarter of
implementation.

Williams also shared about the addition of two new staff members, Dr. Melanie Booth, Director of
Educational Programs and Communications, and Dr, Rachel Christeson, Assistant Director for
Research and Data Analysis. She also shared that a new Director of Information Technology,
Yovani Pina is starting with NC- SARA on November 16, 2020 and would be joining the board
meeting to introduce himself the next day. Mary Larson gave an update on the status of
information technology and other programs at NC-SARA including a refresh of the NC-SARA
website to include the new branding, the searchable student program catalog, and the state
authorization guide.

Belle Wheelan and Barbara Ballard complimented Williams on having accomplished so much in a
short period of time.

     b)    Susan Heegaard, President, Midwestern Higher Education Compact (MHEC)
           President Susan Heegaard of MHEC announced the selection of several SARA
           State Portal Entity staff, SARA participating institution leaders, and board
           members to a board appointed Branch Campus Working Group which will work
           between the Fall 2020 and Spring 2021 board meetings on a report to inform
           branch campus policy. President Heegaard noted that MHEC includes eleven state
           members of SARA, with MHEC sharing North Dakota and South Dakota with
           WICHE, and 500 SARA participating institutions. President Heegaard said that
           MHEC held its annual meeting in July virtually for its SARA regional steering
           committee, with a planned half-day workshop for state portal entities. She also
           shared about the difficulty that some institutions have in adhering to the
           professional licensure policy in place at NC-SARA since its inception, given the new
           federal requirements and NC-SARA board vote to continue this disclosure policy
           in the spring of 2020.

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                     National Council for State Authorization Reciprocity Agreements (NC-SARA)
                                 NC-SARA Board Meeting | Virtual | May 4-5, 2021
c)   Michael Thomas, President, New England Board of Higher Education (NEBHE)
     President Michael Thomas of NEBHE shared that NEBHE includes eight state
     members of SARA and just under 300 SARA participating institutions. He noted that
     since the beginning of the pandemic, 34 institutions from the NEBHE region, about
     four per month, joined SARA as participants. He cited this as a demonstration of the
     ongoing value and evidence of the dynamic nature of higher education institutions.
     President Thomas expressed concern about enrollment declines between 1.5% and
     15% across institutions and states totaling an estimated $1.5 billion in lost tuition
     revenue. He then thanked the three board members cycling off and wished all good
     holidays in spite of the pandemic.

d)   Stephen Pruitt, President, Southern Regional Education Board (SREB)

     Wanda Barker, SREB Division Director, shared the SREB update on behalf of President
     Stephen Pruitt. Ms. Barker shared that SREB includes 16 state members and over
     1,100 participating institutions, over 45% of the total SARA participating institutions. Of
     the total institutions, 93 are HBCUs, and represent 95% of all HBCUs in the US. Ms.
     Barker also reported that four states were renewed as SARA members by the SREB
     regional steering committee earlier inthe fall and their chair and vice chair were re-
     elected to serve an additional term. She also provided an update on the status of
     SREB SARA states appeals process with twelve ready to implement an appeal process
     on January 1, 2021, and eight states working to complete creating such a process.

e)   Demarée (Demi) Michelau, President, Western Interstate Commission forHigher
     Education (WICHE)

     President Demarée Michelau expressed appreciation to President Williams for
     continued improvement and productivity in spite of the pandemic. President Michelau
     said that WICHE has thirteen states and 254 institution and echoed President Thomas’s
     gratitude for the continuing openness in the policy review process with positive
     feedback from the WICHE region. She shared that Lanna Dueck serves as chair of the
     WICHE regional steering committee and there were smooth transitions of members
     of that committee. President Michelau explained that WICHE is now holding monthly
     SARA steering committee meetings to focus on state relationships, collaborative
     discussions, regional issues, and policy development. She also reported that two
     states were renewed in June 2020 and that Nevada held a virtual SARA state meeting
     in October. President Michelau shared that WICHE received an extension to implement
     a compact appeals process and that this is progressing well. Finally, she shared that
     there is continued interest from states and territories in the WICHE region to join
     SARA, thanking President Williams for continued open communication with interested

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               National Council for State Authorization Reciprocity Agreements (NC-SARA)
                           NC-SARA Board Meeting | Virtual | May 4-5, 2021
parties in California, including consumer advocates. Chair Lubbers suggested the board
           take a thirty-minute break before reconvening to break into discussion groups.

Agenda Item III: Small Group Discussions – Teresa Lubbers, Board Chair
Chair Teresa Lubbers invited board members to break into groups to discuss four topics. She
explained that the purpose of the discussions was to engage board members in topics of interest
and concern to NC-SARA without actions for vote. Each group was asked to elect a spokesperson
to report out on the key takeaways from each discussion.
The topics were:

     a)    What is the role of NC-SARA in Quality Assurance in Distance Education?

     b)    How do you see the evolution of governance at NC-SARA?

     c)    What is the current and future role of the regional steering committees?

     d)    What should the action be for NC-SARA, post-COVID when accreditor, federal, and state
           waivers of distance education regulation expire?

Discussion ensued regarding each topic with staff taking notes for potential future board or staff
action.

The first portion of the meeting adjourned at 1:00 pm Mountain Time

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                     National Council for State Authorization Reciprocity Agreements (NC-SARA)
                                 NC-SARA Board Meeting | Virtual | May 4-5, 2021
OCTOBER 29, 2020

Meeting was called to order at 9:00 AM (Mountain Standard Time)
Chair Lubbers opened the meeting with a welcome to all and roll call. All board members
reported as present. In a change to the agenda, she then explained that the Finance Committee
Report would come before the Executive Committee Report.

Agenda Item IV: Finance Committee Report – Leroy Wade, Treasurer

Treasurer Wade directed attention to the fiscal year 2020 financial audit and indicated that the
Finance Committee had no questions or concerns with stable revenue from 2019 to 2020.
Treasurer Wade then asked Director of Finance, Rich Parker, to share additional information
concerning the audit. Mr. Parker said that the audit represents a year of a maturing organization
with no significant or unexpected entries and no comment with feedback sharing process
deficiencies. He also shared that NC-SARA will put out a bid for a new auditor in the coming year
as it is the fifth year with this auditor.

    a)    (ACTION) NC-SARA FY 2020 Audit
          Chair Lubbers called for a motion to approve the fiscal year 2020 financial audit.

              Motion to approve – Leroy Wade
              Seconded – Kathryn Dodge

              Motion carried unanimously with Leroy Wade recusing himself from the vote.

    b)    Q1 FY 2021 Financial Report
          Treasurer Wade reported that the first quarter fiscal year 2020 report reflects a
          stable quarter that is on target and with less than 1% variation from planned
          budget. He also shared that this quarter shows movement of reserves funds into the
          investments planned through implementation of the NC-SARA reserves and
          investment policies.

    c)    Recommendation for the Election of a new Finance Committee Member
          Treasurer Wade shared that with Kathryn Dodge cycling off the board, a
          replacement is needed on the Finance Committee. He said that the committee
          nominates Paul Shiffman given he is not cycling off at the end of 2021 and could
          complete a two-year term, is not also on the Executive Committee, and is not a new
          board member.

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                    National Council for State Authorization Reciprocity Agreements (NC-SARA)
                                NC-SARA Board Meeting | Virtual | May 4-5, 2021
Susan Heegaard raised a concern about Paul Shiffman’s ability to be fair in this capacity given
earlier remarks concerning the need for an audit of the operational structure of NC-SARA including
the role of the regional compacts. Paul Shiffman said he would be fair in his role on the Finance
Committee and Susan Heegaard thanked him. Ed Ray said that in his experience to conduct such an
audit is common practice and that he supports this effort.

Chair Lubbers called for a motion to approve electing Paul Shiffman to the Finance Committee to
replace Kathryn Dodge.

               Motion to approve – Leroy Wade
               Seconded – Peter Smith

               Motion carried unanimously with Leroy Wade recusing himself from the vote.

Agenda Item V: (ACTION): Report and recommendations of the Executive Committee –
Teresa Lubbers, Chair

      a)    Recommendations for the election of Board members

Chair Lubbers explained that the board would turn to the election of three new board members to
three-year terms from 2021 through 2023. There were over 65 nominations and self-nominations
expressing their deep interest in working with NC-SARA moving forward. She said the Executive
Committee was particularly looking to fill gaps in the areas of state regulation, portal entities
and community college representation. Chair Lubbers also called attention to the fact that five
more board members will cycle off at the end of 2021 and seven cycling off at the end of 2022.

Art Coleman asked about the efforts to add an attorney general, consumer advocates and
students to the board. Discussion about these ideas continued with Lori Williams sharing that she is
working to continue conversations with board members in collaboration with consumer
advocates and the National Association of Attorneys General. She also shared that she is
continuing work on a social media plan to ensure outreach to students through connection with
Higher Learning Advocates. Paul Lingenfelter shared that adding Art Coleman and Rob Anderson
to the board was because of their commitment to student wellbeing and work with the Institute
for Higher Education Policy. He added that the board members have a broad perspective and do
not feel a responsibility to argue a particular point of view, focusing on the welfare of students and
higher education.

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Several board members shared words of support for the three nominations. Chair Lubbers called
for a motion to approve electing Angela Lee, Lanna Dueck, and Carlos Morales to the NC-SARA
Board.

               Motion to approve – John Cavanaugh
               Seconded – Belle Wheelan

               Motion carried unanimously.

      b)    Recommendation of Re-Election of Two Board Members

Following a brief discussion regarding the terms for Peter Smith and Larry Tremblay, Chair
Lubbers called for a motion to approve re-electing Peter Smith and Larry Tremblay to a second
three-year term from 2021 through 2023.

               Motion to approve – Barbara Ballard Seconded – Pat O’Brien

               Motion carried unanimously and was subsequently withdrawn by Barbara Ballard
               and Pat O’Brien for more research and a possible later vote via email.

               A unanimous vote to delay was passed. (Following the meeting, it was confirmed
               that in fact Peter Smith and Larry Tremblay had been re-elected at the fall 2019
               meeting to an additional term that runs through the end of 2022.)

      c)    Modification of the NC-SARA Bylaws – Catherine Guttman-McCabe

Chair Lubbers invited Catherine Guttman-McCabe to lead the board through a series of less
substantive changes to the NC-SARA board bylaws, and explained that Mike Goldstein would later
lead a subsequent discussion regarding potential bylaws changes.

Catherine Guttman-McCabe began by mentioning a few global changes and notes. She clarified
that “members” as used in the bylaws refers to the board of directors and that there are no
members of the corporation under Colorado law and in the articles of incorporation. Guttman-
McCabe then led the board through explanation of several edits to the bylaws beginning with
Section 1.

There was a recommendation from Belle Wheelan to edit the number of days prior to board
meeting at which new board members would be elected, to show as 14 to share a list of nominees
with the full board. Additional changes included the addition of a Secretary of the Board as
required by Colorado law, procedures for the election of officers, and the power of the executive
committee between meetings.

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A recommendation was made to exclude the phrase “when travel is not possible,” in Article IV,
Section 2, b, entitled Attendance, in order to emphasize the expectation that board members will
attend in person whenever possible.

A friendly amendment was shared to add the word “board” between “NC-SARA” and “members”
in the first sentence in Article VI, Section 1.

Chair Lubbers also called for a friendly amendment to Article VII, Section 1a, to add the phrase
“of the membership” between “two-thirds” and “vote” in the last phrase of the lastsentence.

Chair Lubbers also called for a vote to approve the bylaws changes as amended.

                Motion to approve – Stephen Pruitt
                Seconded – John Cavanaugh

                Motion carried unanimously.

      d)    Discussion of NC-SARA Bylaws Issues – Mike Goldstein

Discussion began with issues related to the election of board members and officers. There was
general agreement that when possible, it is preferable for board members to have had a year of
experience prior to service as officers. It was also agreed that the Vice Chair assumes the role of
Chair, unless there is reason to believe that Vice Chair will not serve ably, and that this
assumption does not require a change to the bylaws, but represents process. Others suggested a
possible policy statement regarding this practice over including this provision in the bylaws.
Opinions were shared about whether a board member replacing someone leaving earlier than a
full term continues that term and then has additional three-year terms, or not. This issue will
require additional discussion and agreement to clarify this issue in the bylaws.

The next bylaws issues discussed pertained to the Executive Committee. It was agreed that the
rotation schedule for committee appointments of the regional compact presidents would be
shared with the board and additional clarification added to the bylaws at a later date. Clarification
regarding the role of the Finance Committee in working with NC-SARA staff, and the Finance
Director specifically, to identify an auditor was already addressed in the bylaws revisions.

A brief discussion took place regarding the role of the Executive Committee in setting the agenda
for the full board. Goldstein explained that it is common practice for the Executive Committee to
set the board agenda with the President and that board members have the ability to raise issues
at a meeting without going through the Executive Committee. There was also discussion about
how any board member might add new business to the agenda. Finally, Goldstein expressed his
and Catherine Guttman-McCabe’s surprise and concern that the bylaws contain a provision in
Article six, regarding the manner in which the president communicates with the board. He

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strongly recommended deleting this entire section as it represents procedure over policy.

Agenda Item V: (ACTION): Modifications to the SARA Policy Manual

After explaining that there were six proposed modifications for board consideration, discussion
and vote, with the first modification being called for a vote separately from the other five, Chair
Lubbers invited President Williams and her team to explain the rationale for the modifications.

Policy Change Modification

      a)    (ACTION) Approve Section 3.2 change to add one additional reason that a state might
            put an institution on provisional status.

Following a comment from Stephen Pruitt to note that NC-SARA must be clear with states about
what is not negotiable and when states have flexibility, Chair Lubbers called for a motion to
approve.

                Motion to approve –Larry Tremblay
                Seconded – Leroy Wade

                Motion carried unanimously.
Policy Clarification Modifications

      b)    (ACTION) Approve Section 1 modification to add a phrase regarding non-credit bearing
            courses to the definition of “Operate.”

 No board discussion followed the explanation for this modification.

      c)    (ACTION) Approve Section 2.6(c) modification to replace the word “it” with “the
            Compact” for clarity of reference.

 A friendly amendment was requested by Patricia O’Brien to replace the word “themselves” with
 “itself” in the red lined version of the modification. No additional board discussion followed the
 explanation for this modification.

      d)    (ACTION) Approve Section 3.1(b)(6) modification to language to align with application
            requirements for all institutions when programs are no longer offered

 No board discussion followed the explanation for this modification.

      e)    (ACTION) Approve Section 4.4(g) modification to delete the word “issues” in the
            context of the section regarding mandatory arbitration.

 No board discussion followed the explanation for this modification.

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f)    (ACTION) Approve Section 8.2(a) modification to add a phrase to specifically indicate
           that input on policy is expected from institutions and other key stakeholders and
           brought to the attention of NC-SARA.

Following a couple of clarifying questions from Susan Heegaard and Robert Anderson, which were
answered by President Williams, Chair Lubbers called for a motion to approve the five
modifications.

               Motion to approve – Robert Anderson
               Seconded – Paul Shiffman

               Motion carried unanimously.

Agenda Item VI: Executive session

Agenda Item VII: Questions, comments, reflections from Board members

Adjourn

Meeting was adjourned following a private executive session.

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Agenda Item II: Update on NC-SARA Progress

Action Item:                 ☐ Yes            ☒ No

Background: NC-SARA began inviting states to join in early 2014. As of May 2021, 49
states plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands -- are
members. Discussions continue in California. 2,265 institutions participate in SARA as
of April 7, 2021.

Lori Williams will provide an overall assessment. Regional compacts will focus on
SARA developments within their regions.

a)     Lori Williams, National Council for State Authorization
Reciprocity Agreements (NC-SARA)
               a. Update on Strategic Plan progress
               b. Update on Communications Plan and Educational Programming
               c. Update on Website Refresh
               d. Update on Information Technology
               e. Update on Enrollment Data and Cost Savings Study
               f. Consumer Protection Update Impacting SARA
               g. State Authorization Guide and Professional Licensure Directory
               h. SARA Source
               i. In the Field NC-SARA Institution Conference

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Agenda Item III: Update from Regional Compacts on SARA

Action Item:     ☐ Yes           ☒ No

  a)   Susan Heegaard, Midwestern Higher Education Compact (MHEC)
  b)   Michael Thomas, New England Board of Higher Education (NEBHE)
  c)   Stephen Pruitt, Southern Regional Education Board (SREB)
  d)   Demarée Michelau, Western Interstate Commission for HigherEducation (WICHE)

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Agenda Item IV (ACTION): Report and recommendations for the Executive
Committee – Teresa Lubbers, Chair

Action Item:                 ☒ Yes            ☐ No

     a)    Update on Policy Review meeting discussion
     b)    Update on succession planning

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Agenda Item V (ACTION): Finance Committee report - Leroy Wade, Treasurer

Action Item:      ☒ Yes           ☐ No

     a)    Third-quarter FY 2021 Finance Report
           The finance report will be provided under separate cover.
     b)    Investment of Reserves
           Update provided by Colorado Financial Management (Charles Schwab)
     c)    (ACTION) Approval of the NC-SARA Budget for FY 2022-23
           The proposed FY 2022 budget will be provided under separate cover.

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Agenda Item VI (ACTION): Federal Higher Education Landscape Impact on
NC-SARA – Catherine Guttman-McCabe

Action Item:                 ☐ Yes            ☒ No

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Agenda Item VII: Update on 21st Century Distance Education Guidelines – Sally
Johnstone and Barbara Brittingham
Action Item:    ☐ Yes           ☒ No

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Agenda Item VIII: Branch Campus Working Group – Belle Wheelan and
Susan Heegaard

Action Item:                 ☐ Yes            ☒ No

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Agenda Item IX (ACTION): Modifications to the SARA Policy Manual

Action Item:        ☒ Yes            ☐ No

Policy Change Modifications

    a) Approve Section 3.2(a)(8) change to extend provisional status period under certain
       circumstances.
    b) Approve Section 3.2(e) change to extend provisional status specific to change of
       ownership, for ongoing investigation, or for an extension of an accreditation
       probationary period.
    c) Approve 3.2(g)(2) policy language to align with changes in Section 3.2(e).
    d) Approve removal of Section 8.3 to combine with Section 8.2 to ensure all policy
       modifications are treated the same.

Policy Clarification Modifications

    e) Approve Section 2.2(b) change to update the appeals language to reflect the
       implementation of the policy by the passed deadline.
    f) Approve Section 2.5(c) change to update the language to related to the federal
       financial responsibility composite score (FRCS) pertaining to institutions and parent
       companies.
    g) Approve Section 2.5(d) change to update the appeals language to reflect the current
       implementation of the policy.
    h) Approve Section 2.6(c) change to update the appeals language to reflect the current
       implementation of the policy.
    i) Approve Section 3.8(c) policy language to align with the now implemented appeals
       process.
    j) Approve 5.10(b) policy change to remove the word “academic.”
    k) Approve 6.2 policy change to remove screen shots associated with the process of
       submitting institutional enrollment data.

Policy Change Modification- 21st Century Guidelines and C-RAC Guidelines
    l) Approve 4.7 incorporation and transition to use of the 21st Century Distance
        Education Guidelines to replace the retired 2011 C-RAC Interregional Guidelines for
        the Evaluation of Distance Education (policy modification)

Proposed Modifications to the SARA Policy Manual
There are 12 proposed changes to the SARA Policy Manual. These are policy changes
recommended by the states, compacts, and NC-SARA staff as indicated below. There are five

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(5) policy modifications and seven (7) policy clarifications.

Recommendation: Approve the proposed modifications.

Background. The SARA Policy Manual is issued periodically by NC-SARA; the current
version is Version 20.3, issued October 30, 2020, following the fall 2020 meeting. Successive versions
incorporate policy changes made by the NC-SARA Board and clarifications provided by the staff of NC-
SARA. The recommended modifications that follow, if approved, will result in a new Version 21.1
which will go into effect immediately following an affirmative board vote and will be released on the
NC-SARA web site within 30 days.

Policy Change Modifications
    a) (ACTION) Approve Section 3.2(a)(8) change to extend provisional status period under certain
    circumstances

Background: This change provides additional language to Section 3.2(a)(8) to ensure that a state has
the option to start a new provisional period for a change of ownership that will not count against the
provisional clock. This policy change will allow for a possible extension of provisional status in a
situation in which an institution is waiting to receive its new Federal Financial Responsible Composite
Score (FRCS). The additional time will not necessarily indicate greater risk of institutional closure and
in some cases the opposite is the case. This modification was proposed by MHEC and NC-SARA staff.

Alternatives Considered and Rationales
    1) Do Nothing Scenario – Not Recommended
       Leaving the policy unchanged puts students at risk of losing their programs in those
       situations in which their institution has been on provisional status for financial issues and a
       new owner takes over.

    2) Attempt to revise all provisional status policy now to include additional
       recommendations. - Not Recommended
       NC-SARA staff received additional recommendations for policy revisions to include
       more aspects of provisional status. These recommendations for this specific policy
       revision as well as the others proposed at this board meeting that pertain to
       provisional status were considered. After discussions with the four regional
       compacts and several board members, it was determined that it is best to put
       forward these policy proposals regarding provisional status at this time and review
       additional possible revisions before another board meeting.

    3) Revise policy to update given the date for state compliance has passed. – Recommended
       Changing the policy to allow states more leeway in permitting a new provisional status period

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for institutions under new ownership. The additional time may allow the institution to have its
        new finances reviewed to obtain a new FRCS. As a result, the institution may remain in
        business and its students continue their programs.

See red lined version of recommended modification below.

3.2 Provisional admission or renewal of an Institution
        a. A state, at its discretion, may approve an institution applying for initial or renewal
        participation in SARA to participate on Provisional Status in any of the following
        circumstances:
        1. The Institution is on provisional or probationary status or the equivalent with its
        institutional Accrediting Agency;
        2. The Institution is currently required by the U.S. Department of Education to post a
        letter of credit or is under a cash management agreement with the U.S. Department of
        Education (such institutions must still have a Federal Financial Responsibility
        Composite Score of 1.0 or above);
        3. The Institution has a Federal Financial Responsibility Composite Score between 1.0
        and 1.5;
        4. The Institution is the subject of a publicly announced investigation by a government
        agency, and the investigation is related to the institution’s academic quality, financial
        stability or student consumer protection;
        5. The Institution is the subject of a current investigation by its Home State related to
        the institution’s academic quality, financial stability or student consumer protection;
        6. A third-party action such as a private lawsuit or news story does not by itself
        establish a government investigation. If such a third-party event results in an
        investigation by a government agency as set forth in subsections 3 and 4 above, these
        subsections become applicable. Lawsuits by government entities are considered to
        have resulted from a governmental investigation and can be the basis of a
        determination of Provisional Status.
        7. Lack of compliance with SARA policies related to data reporting.
        8. The Institution has a change of ownership as determined by the Home State.
        Additional changes of ownership of the same institution constitute a separate basis
        for a state’s determination of provisional status. Each such determination begins a
        new period of provisional status under Section 3.2(e).
        9. The participating institution is in violation of, or noncompliance with SARA policies.

    b) (ACTION) Approve Section 3.2(e) change to extend provisional status specific to change of
    ownership, for ongoing investigation, or for an extension of an accreditation probationary period.

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Background: This change provides additional language at 3.2(e) to ensure enough time when an
institution may need to extend provisional status due to financial calculations at the federal level or
for an investigation. This will allow for a possible extension of provisional status in a situation in
which an institution is waiting to receive its new Federal Financial Responsible Composite Score. The
additional time will not necessarily indicate greater risk of institutional closure and in some cases the
opposite is the case. The additional language will ensure continued provisional status during an
ongoing investigation or accreditor probationary status that has not been completed in two years.
This modification was proposed by MHEC and NC-SARA staff.

Alternatives Considered and Rationales
    1) Do Nothing Scenario – Not Recommended
       As indicated above in recommending the changes to section 3.2(a)(8), leaving the policy
       unchanged puts students at risk of losing their programs in those situations in which their
       institution has been on provisional status for financial issues, an investigation, or an extended
       accreditor probationary period.
    2) Revise policy to extend provisional status specific to change of ownership, for an
       ongoing investigation or extended accreditor probationary period. – Recommended
       Changing the policy allows states more leeway in permitting an extended provisional
       status period for institutions undergoing a change of ownership, or under
       investigation by another agency. The additional time may allow for the completion of
       the investigation and determination of institution compliance with SARA policy.

See red lined version of recommended modification below.

Section 3.2(e). In no event shall such an extension of Provisional Status exceed one
additional year. An extension of Provisional Status shall not exceed one additional year
unless a change of ownership has occurred during the current period of provisional status
and additional time is needed to demonstrate compliance with federal requirements, or the
institution is on provisional or probationary status or the equivalent with its institutional
Accrediting Agency, or there is an ongoing investigation as described in Section 3.2(4) and
(5).

    c) (ACTION) Approve 3.2(g)(2) policy language to align with changes in Section 3.2(e).

Background: This change clarifies policy language in Section 3.2(g)(2) to align with
recommended edits to Section 3.2(e). This modification was proposed by MHEC and NC-SARA
staff.

Alternatives Considered and Rationales

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1) Do Nothing Scenario – Not Recommended
       Assuming Section 3.2(e) is revised as recommended, this section must also be revised to
       align.
    2) Revise policy to align with recommended revision to Section 3.2(g)(2) – Recommended
       This is an additional policy section that would require revision to permit extensions
       of provisional status under specific circumstances.

See red lined version of recommended modification below.

Section 3.2(g): If an Institution on SARA Provisional Status is found by its home state to not meet the
requirements of SARA, the home state shall disallow any further enrollments under SARA, shall notify
its Regional Compact and NC-SARA, and:
        1. Remove the institution from SARA participation, or
        2. Allow the institution a period of time not to exceed 12 months in which to come into
        compliance with SARA policies under state supervision. Only one such time period is allowed
        in any three-year period, unless the extension is due to an ongoing investigation or as a result
        of a change of ownership during the current period of provisional status and additional time is
        needed to demonstrate compliance with federal requirements.

    d) (ACTION) Approve removal of Section 8.3 to combine with Section 8.2 to ensure all policy
    modifications are treated the same.

Background: This change removes section 8.3 to combine with 8.2 to remove distinctions
between types of policy changes. The subjectivity associated with the previous distinctions
made between types of changes has proved problematic. Without this difference, all
modifications are treated the same. This modification was proposed by NC-SARA staff with
input from regional compact staff, SARA State Portal Entity staff and other stakeholders. A
section describing process, which is not usually included in policy, was recommended by
WICHE to remain.

Alternatives Considered and Rationales
    1) Do Nothing Scenario – Not Recommended
       Not changing this policy section will continue to describe distinctions in policy
       types that are no longer made.
    2) Revise policy to align with recommended revision to Section 3.2(e). – Recommended
       This change will remove differences in types of policy modifications such that all are
       considered with openness and transparency.

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See red lined version of recommended modification below.

        8.2 Minor Modifications
        a.       Process: Questions, comments, or suggested modifications to SARA policies, from
        institutions and other key stakeholders, may be brought to the attention of:
        •       SARA State Portal Entity (SPEs) portal entity directors in SARA member
        states;
            •   SARA directors in the Regional compacts;
            •   Regional SARA regional steering committees; or
            •   The President or staff of the National Council for State Authorization
                Reciprocity Agreements (NC-SARA).

Persons making such requests should provide a rationale supporting their request. Such
request will normally be considered at the state level first, followed by consideration by the
relevant SARA regional steering committee. If any such request gains the approval of the
regional compact’s SARA steering committee, the President at earliest opportunity shall
share place that request on the agenda of the NC-SARA Executive Committee of the Board for
its consideration, or if necessary, make other arrangement for Board consideration.

Such communications shall be dealt with in as expedient a manner as possible, while
ensuring broad consultation and consistency across the SARA community. Unresolved
questions, concerns, or comments shall involve further consultation among SARA State Poral
Entity (SPEs) portal entity directors, regional compacts and NC-SARA staff. The NC-SARA
President and NC-SARA staff shall work with regional directors compacts to develop and/or
propose responses. As appropriate, that process may include consultation with the SARA
regional steering committees in the regional compacts and with the NC-SARA Board. The
President of NC-SARA is responsible for ensuring that responses are developed.

In responding to and ultimately acting on such requests, NC-SARA staff and the regional
compacts shall evaluate proposed changes in light of SARA’s fundamental reliance on
interstate reciprocity and trust, and on the fundamental purposes of SARA, which are to
support high quality distance education, resolve problems encountered by students, and
simplify and support the interstate offering of distance education using a model under which
an institution’s home state is primarily responsible for what the institution offers under the
aegis of SARA.
Other guiding principles for the review, clarification and modification of SARA policies include:
•   Broad consultation with stakeholders;
•   Maintaining consistency in policy and procedures;
•   Transparency and openness; and
•   Responsiveness to stakeholders and emerging policy issues.

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b. Minor Modifications: The President may approve and promulgate clarifications and minor
modifications that do not substantively change SARA Policies, after concluding the
consultative process described above.
8.3 Significant modifications
Ultimately, it is the responsibility of the President and CEO of NC-SARA to ensure broad
consultation among the Regional Compacts, NC-SARA, and the SARA community at large in
developing responses to requests for significant modifications to the SARA Policy Manual.
Requests for significant changes should be addressed to the President and CEO of
NC-SARA, who will work with the Regional Compacts, their SARA steering committees, the
NC-SARA executive committee, and the NC-SARA Board to ensure consideration and
resolution. Persons making such requests should provide a rationale supporting their
request. Such requests will normally be considered at the state level first, followed by
consideration by the relevant SARA regional steering committee. If any such request gains
the approval of a regional compact’s SARA steering committee, the President at earliest
opportunity shall place that request on the agenda of the NC-SARA Board for its
consideration, or, if necessary, make other arrangements for Board consideration.
        In responding to and ultimately acting on such requests, regional and national SARA staff and
        oversight committees shall evaluate proposed changes in light of SARA’s fundamental
        reliance on interstate reciprocity and trust, and on the fundamental purposes of SARA, which
        are to support high quality Distance Education, resolve problems encountered by students,
        and simplify and support the interstate offering of Distance Education using a model under
        which an Institution’s Home State is primarily responsible for what the Institution offers
        under the aegis of SARA.
        Other guiding principles for the review, clarification and modification of SARA policies include:
        •       Broad consultation with key stakeholders;
        •       Maintaining consistency in policy and procedures;
        •       Transparency and openness; and
        •       Responsiveness to stakeholders and emerging policy issues.

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