When the Higher Education Act was last reauthorized as the Higher Education Opportunity Act, a new provision was included that required institutions of higher education participating in Title IV programs to be able to document compliance with laws in all states where they offer distance or correspondence education. The provision is included in the U.S. Department of Education’s (ED) Program Integrity rules [PDF], 34 C.F.R. § 600.9(c), published in 2010. Although ED has not implemented this provision, its inclusion called attention to states’ processes requiring universities to seek approval for educational activities being conducted or received outside of the home state.
A complicating factor relates to the variations among states in how distance education is defined, including what constitutes “physical presence.”
For example, one state may require authorization for any student completing any activity for which he/she receives academic credit, including clinical practicum, while a neighboring state may exclude clinical practicum or fieldwork activities as a trigger and, hence, require no authorization.
State Authorization for Clinical Practicum Placements (Quick Reference)
ASHA’s quick reference resource [PDF] outlines whether authorization may be required for clinical practicum placement outside of the home state of the university. This resource is meant to assist those responsible for coordinating students’ clinical practicum placements in identifying when the university may need to take additional steps to secure required authorizations. Specific questions regarding the application and verification should be directed to the contact listed for each state.
State Higher Education Executive Officers Association (SHEEO)
Since the 2010 publication of ED’s Program Integrity Rules, much work has been done nationwide to consider and establish a reciprocity agreement among the states to ensure consistency in definitions, costs, and other matters for state authorization of postsecondary education. SHEEO has conducted a series of surveys and maintains on its website resources and reports related to this topic, including the results of the April 2014 survey mentioned above, a contact list for state authorizing agencies, and links to current activities for the National Council for State Authorization Reciprocity Agreements (NC-SARA).
