Hello hello!

Happy September everyone!

The SARA policy proposal and approval process continues to move along and late last week they released the proposals that were approved by the regional compacts to move forward. Of the 50+ new policy proposals or changes, only 6 are moving forward to a Board vote.

1. Modification PMP‐0356: SPE removal of provisional status
2. Modification PMP‐0368: SARA Policy Manual
3. Modification PMP‐0373: Provisional Notification‐ Add (i) to Section 3.2
4. Modification PMP‐0383: Modification of Language: ArbitraƟon Agreements
5. New Policy PMP‐0330: Require NC‐SARA to notify public of institution status
6. New Policy PMP‐0331: Institutional disclosure requirements

Personally I am waffling between a state of concern, confusion, and ambivalence. None of these modifications or additions involve language that concerns me or creates a new burdensome requirement. The only one of the above that might have an affect on our work would be PMP‐0331 Institutional Disclosure Requirement. This new policy, if passed would require institutions to make a public disclosure about any adverse action on our institutions by the state of Colorado or any other oversight entity related to academic quality, financial stability, student consumer protection, or compliance with any state or federal requirements. We'd also be required to notify CO if there is a change in our operations as an institution that would be inconsistent with what we're required to do as SARA participants as outlined in the SARA Manual. But this requirement for notifications of adverse actions isn't really new. We're already required to do this as part of our accreditation with HLC. This just ropes those of us in state‐authorization land into that notification requirement officially.

But the other proposed modifications/changes? M'eh. These feel like low hanging fruit. Like the folks at NC‐SARA are trying to remain as milquetoast as possible while they work on hiring a new President and we wait to see what happens at the Federal level....

And I'm mad that 5.2 remains unchanged and "all reasonable efforts" will continue to exist and allow for all sorts of interpretations and headaches.

In any event, the above will move forward to the NC‐SARA Board later this Fall for a review and vote.

In other news ‐ I wanted to talk about another form email/canned conversation I have handy relating to state authorization. At Boulder, I get copied on changes in our Course Inventory Management (CIM) system because there are a couple of areas that require me to have some oversight and knowledge of what is changing or being added. Faculty who add or change courses are asked the following questions:

• Does this course require a teaching or experiential learning component that may be taken by a student outside of Colorado in a given semester?
• Is it possible for more than 10 students to be enrolled at any given experiential learning site at the same time?

Inevitably the faculty completing this form answer "YES" to both questions without a second thought.... which resulted in them getting an email from me that notes:

For the course [COURSE CODE & NAME], it’s indicated that the course “requires a teaching or experiential learning component that may be taken by a student outside of Colorado in any given semester” and that it is “possible for more than 10 students to be enrolled at any given experiential learning site at the same time.”

"Experiential learning" refers to particular course types, such as internships, clinical placements, practica, or student teaching. This course appears to not be one of those types of courses. Additionally, current regulations pertaining to state authorization require that we track where our students will be taking these out of state learning opportunities and contact them in regard to certain required notifications and further that we are not permitted to have more than 10 students at any one experiential learning site outside of CO at a time.

This happens so frequently that yes, I have a whole form email, yes I have been working with the registrar's office to change the language and workflow on the CIM form, and yes I have gotten to know quite a few faculty because of our interactions about what "experiential learning" actually means, the history of reciprocity and why we can't have 11 students at a single office in Manhattan but 11 in Denver is okay.

Boulder is looking to make some other changes to CIM relating to changes to programs (such as adding a modality and asking about my other favorite topic, regular & substantive interaction) and will be updating this section once again to assist faculty in learning about course types and the impact on state reciprocity.

How do you define and track experiential learning? And how do you communicate that with the myriad of departments and programs on your campus? And did you know that CO's workers comp laws are worded and enforced in such a way that many institutions from outside CO won't send their students here for experiential learning? Some institutions (e.g. Ohio State) actually grey us out on their maps. MORE FOR US I say!

And with that ‐ I hope you're all having an excellent week! The ED is still being suspiciously quiet and as such there are all sorts of conflicting rumors about what may or may not be released in the next 6 weeks. Fingers crossed that they get so wrapped up in the student loan crisis that they forget about some of the stuff they proposed in May.

Erika G. Swain
Associate 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

“Today I will be a Bulgarian Minister of Education,” Bokonon tells us. “Tomorrow I will be Helen of Troy.” – Vonnegut, Cat’s Cradle