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State Authorization

The Office of Academic Program Review, Assessment, and Accreditation, in collaboration with Vanderbilt’s campus partners, is responsible for monitoring the status of state and federal guidelines regarding distance education and activities outside of Tennessee. Each state has enacted laws and regulations to oversee activities by educational providers and determines when an institution has crossed a statutory threshold into regulation. Though each state is different, regulations can apply to multiple types of educational activities, including distance education, clinical placements, in-person instruction, promotional activities, or other regulated activities within a particular state.

In 2010, the U.S. Department of Education issued a regulation tying an institution’s ability to offer federal financial aid in a state to the institution being authorized in the student’s state. The regulation, 34 CFR 600.9 (c), was subsequently “vacated” by a federal court ruling and is therefore unenforceable. Though the federal enforcement of this particular law is on hold for now, the current state laws for distance education authorization remain intact. The Office for Planning and Institutional Effectiveness is working with the necessary state agencies to ensure compliance with applicable distance education regulations. Questions or concerns regarding distance education regulations should be sent to

State Status and Reciprocity

Vanderbilt University is authorized on a state level primarily through the Tennessee Higher Education Commission and is also an institutional member of the National Council for State Authorization Reciprocity Agreements (NC-SARA), a voluntary and regional method to oversee distance education. Through NC-SARA membership, Vanderbilt can offer distance education programs in states who are also NC-SARA members without further approval from that particular state. See below for more information regarding the university’s membership and participation in NC-SARA:

The University is allowed to have students enrolled in distance education programs and/or be placed in supervised field experiences in the NC-SARA states (non-bold typeface) listed in the table below. The remaining states are non-SARA states (bold typeface), and they may require authorization/approval depending on the activity or activities being conducted. Please contact the Office of Academic Program Review, Assessment, and Accreditation if you have an interest in distance education programs and/or supervised field experiences in non-SARA states.

Alabama Florida Louisiana Montana North Dakota Tennessee
Alaska Georgia Maine Nebraska Ohio Texas
Arizona Idaho Maryland Nevada Oklahoma Vermont
Arkansas Illinois Massachusetts New Hampshire Oregon Washington
California Indiana Michigan New Jersey Pennsylvania Washington D.C.
Colorado Iowa Minnesota New Mexico Rhode Island West Virginia
Connecticut Kansas Mississippi New York South Carolina Wyoming
Delaware Kentucky Missouri North Carolina South Dakota Virginia
(bold typeface = non-SARA states)


Activities Permitted and Not Permitted Under SARA

Membership in NC-SARA permits institutions to engage in many educational activities within other SARA states. Activities that involve a more substantial physical presence may require additional authorization and are not covered under the reciprocity agreement. Please review the list below and contact if you have a potential out-of-state program or activity that would trigger physical presence.


Educational Activities Covered Under SARA

  • Offering courses to individuals via distance education in ways that do not require students to gather physically in groups, excepting the special provisions in Section 5 in the SARA Policy Manual;
  • Advertising to students whether through print, billboard, direct mail, internet, radio, television, or other media;
  • Offering distance education courses on a military base or vessel if enrollment in such courses is limited to active and reserve military personnel, their dependents, and civilian employees of the installation;
  • Maintaining a server, router, or similar electronic service device housed in a facility that otherwise would not constitute physical presence (the presence of a server or similar passthrough switching device does not by itself constitute the offering of a course or program in that state);
  • Having faculty, adjunct faculty, mentors, tutors, recruiters, or other academic personnel residing in a member state and working from their homes or another private, non-institutional site, provided that such staff is not engaged in activities that would otherwise constitute physical presence as defined by these Policies and Standards;
  • Holding proctored exams on behalf of the institution in the host state;
  • Having contractual arrangements in the home or host state, e.g. procurement contracts or course offerings through consortium agreements;
  • Operating limited supervised field experiences (See Subsection 5.11 – Supervised Field Experiences);
  • Using recruiters in a SARA member state; (This provision is not restricted to recruiting for courses or programs offered under SARA, and does include athletic recruiting).
  • Engaging in field trips to visit existing sites or facilities for academic purposes not involving the establishment of residential or instructional facilities.

Physical Presence Educational Activities Not Covered Under SARA (may require additional authorization)

  • Establishing a physical location for students to receive synchronous or asynchronous instruction;
  • Requiring students to physically meet in a location for instructional purposes more than twice per full-term (quarter or semester) course for a total of more than six hours;
  • Establishing an administrative office;
  • Providing information to students to enroll students, or provide student support services from a physical site operated by or on behalf of the institution in the state;
  • Offering a “short course” that requires more than twenty contact hours in one six-month period;
  • Providing office space to instructional or non-instructional staff;
  • Maintaining a mailing address or phone exchange in the state;
  • Carrying out field study or field research located at a field station, research station, or another physical site at which a faculty member or other institutional employee or contractor supervises or otherwise directs two or more students in an activity exceeding the allowable short course length and which either bears academic credit or is a requirement for a course or program;
  • Having a supervised field experience* of more than ten students from an individual academic program placed simultaneously at one clinical or practicum site.

*supervised field experience = 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 the enrolling SARA institution.


Distance Education Complaint Process

Students enrolled in distance education programs or courses offered by Vanderbilt University in states other than Tennessee should seek resolution for complaints first through Vanderbilt’s complaint procedure.

For out-of-state students using distance learning programs in National Council for State Authorization Reciprocity Agreements (NC-SARA) states, complaints related to consumer protection laws shall be filed using the Tennessee NC-SARA Portal form. For out-of-state students using distance learning programs in non-NC-SARA states, students may contact the appropriate authority in their state of residence.

Additional information about the student complaint and grievance procedures for both on-campus and distance students (if applicable) may be found in each school’s catalog.



Does your program, course, or activity take place outside the state of Tennessee?

If no, no action is needed.


If yes, does the program, course, or activity take place in a SARA state?

If no, contact


If yes, does the program, course, or activity involve any of the nine physical presence triggers in the SARA state (see parameters in the previous section)?

If no, contact


If yes, the program course or activity may need to be approved by the applicable out-of-state higher-education agency. Contact

Licensure and Certification Disclosures

Institutions are required to make public whether a program will fulfill educational requirements for specific professional licensures or certification required for employment in an occupation if the program is designed to or advertised as meeting such requirements. Please visit program websites for details.