Hi everyone & happy start of the Fall Semester!

As we begin the semester and we all take our various roles in our campuses work to improve and optimize learning for our students, I wanted to draw your attention to a somewhat forgotten part of state authorization and SARA participation - courses and programs being offered on Coursera.

Regardless of the courses being credit bearing or the programs being financial aid (Title IV) eligible, if we are offering education to a student outside of CO and they are paying our university, the delivery of that education is covered by our participation in SARA. And yes, even the MOOCs.

But Erika, a MOOC isn’t distance education, there’s no regular and substantive interaction! I know, but SARA defines distance education as:

instruction offered by any means where the student and faculty member are in separate physical locations. It includes, but is not limited to, online, interactive video and correspondence courses or programs.

So yes, again, even the MOOCs (which fall under the correspondence umbrella).

What does this mean for us then? This means we still have to have a way to indicate to the students some of the consumer information information as required by SARA, such as information on state authorization, and information on how to file a complaint. Student complaints was an enormous part of the formation of SARA and is an over all must-do for all colleges and universities. Your students must be informed on how they can send in/make a complaint as necessary, regardless of program, enrollment, or modality.

Think about it this way - learning is learning, and students are students. We’re still charging them $ and giving them a piece of paper (digital or real) that conveys they have achieved something. So even if Boulder is charge $50 for a 2 course MOOC program in knitting, Boulder still has the responsibility to convey to the student that we are in fact behaving responsibly and complying with interstate regulations regarding the delivery of that education. In addition by complying with SARA policies in the delivery of that course we are not getting the knitting guild of NV up in arms as some rogue knitting school who may not follow .... Sorry I don’t actually know how to knit so I’ve lost the metaphor, but I suspect at this point you understand why we comply with state authorization regulations.

In addition to student complaint notifications, professional licensure regulations don’t stop just because a student is enrolled in a program via coursera. In the NC-SARA manual, section 5.2, while NC-SARA notes that they have no effect on state licensure requirements,

Any institution approved to participate in SARA that offers courses or programs designed to lead to professional licensure or certification or advertised as leading to licensure must satisfy all federal requirements for disclosures regarding such professional licensure programs under 34 §C.F.R. 668.43.

This means that, again, regardless of credit or the applicability of financial aid, if your institution is offering a course or program via coursera that does, is intended to, or could conceivably lead to a professional licensure or certification, you are required by SARA to provide those students (prospective and enrolled) with the same general and direct notification as the students who take professional licensure programs on-campus or via distance education.

But Erika, our faculty do that on their own or with the assistance of System. Your campus is still responsible. System doesn’t participate in SARA, the campuses do. System is not eligible to be a SARA participant. System is also not recognized as a provider of credentials, the individual campuses are.

Have a wonderful rest of the week and if you have any questions, please don’t hesitate to reach out!

Sincerely,

Erika

Erika G. Swain
Interim Assistant Director for State Authorization
Office of Academic Affairs
University of Colorado System
e: swaine@cu.edu
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Assistant Director for Compliance and Authorization
Office of Data Analytics | Office of Institutional Research
University of Colorado Boulder
e: Erika.Swain@colorado.edu
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o: (303) 735-8184
c: (518) 637-9785