Compliance and Ethics
NC-SARA stands for the National Council for State Authorization Reciprocity Agreements
- (NC-SARA) more commonly known as SARA.
- SARA represents a reciprocity agreement in which member states agree to grant each other the right to provide online education in other member states subject to agreed upon limitations.
- Currently 49 states are members of SARA: For a list of SARA states, please see the State Actions page.
- In states who are not participating in SARA at this time, the institution must look at the state specific statutes.
- Mississippi became a member of NC-SARA on 1/1/16.
- USM applied for and was accepted as a participating institution of SARA on 3/31/16
USM is authorized to offer distance education in all states listed as NC-SARA states (see the Mississippi NC-SARA page).
All states are participants in the NC-SARA reciprocity agreement except California. Two US Protectorates are also participants in NC-SARA:
U.S. Virgin Islands and Puerto Rico.
The other inhabited US Protectorates (i.e. American Samoa, Guam, Northern Mariana Islands) are not members of NC-SARA.
Both Palau and the Republic of the Marshall Islands are sovereign states in free association with the United States and are not members of NC-SARA.
In California, public institutions do not have a regulatory agency. Private institutions are regulated by the Bureau for Private Postsecondary Education, which only regulates for-profit institutions. Although California does not have a regulating agency, they have assigned the receipt of complaints to the California Department of Consumer Affairs; and the form for filing a complaint is posted on the California Department of Consumer Affairs website.
- As a participating institution, USM is now able to:
- offer distance education (both online and limited field experiences) to students in any SARA State
- advertise and recruit as long as we do not engage in any of the following activities
within member states:
- Create a physical location for students to receive synchronous or asynchronous instruction;
- Require 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;
- Establish an administrative office;
- Provide information to students for the purpose of enrolling students, or providing students support services, form a physical site operated by or on behalf of the intuition in the state;
- Offer a “short course” that requires more than 20 contact hours in one six-month period;
- Provide office space to instructional or non-instructional staff;
- Maintain a mailing address or phone exchange in state;
- Carry out field study or field research located a field station, research station or other physical site at which a faculty member or other institutional employee or contractor supervisors or otherwise directs two or more students in an activity exceeding the allowable short course length set forth in section 5.4 (as of 2/5/24-"no more than 20 classroom hours in one six-month period.") or engages in class meetings of "no more than two meetings, totaling six hours or fewer".
To provide education to students residing in other states, which constitutes operating in another, higher education institutions must comply with the laws and regulation of each of the states in which students are located while completing distance education. Distance education includes online as well as supervised field experiences including clinicals, internships, externships, and practicums. Per Section 1 (31) of the National Council of State Authorization Reciprocity Agreements (NC-SARA), operating is defined as "activities conducted by an institution in support of offering distance education degree or non-degree courses or programs, and non-credit bearing courses in a state, including but not limited to instruction, marketing, recruiting, tutoring, supervised field experiences, experiential learning placements, out-of-state learning placements and other student support services."
In addition to being authorized directly or operating pursuant to a reciprocity agreement, an institution must also check with the state professional licensing boards to see if any program that they are offering that involves distance education requires preapproval before a supervised field experience is conduct and leads to licensure in the state the students is located or where they complete their supervised field experience.
Whether or not a higher education institution engages in an action that triggers “physical presence” varies based on the laws of each specific state. Among the activities considered in determining if physical presence is triggered are:
- hosting short-term, face-to-face, seminars or conferences where students meet in person
- experiential learning within the jurisdiction (field experience, clinical, internship, externship, practicum) organized by the institution
- owning property within a state
- recruiting done in an organized manner, consistently, and on-the-ground either by employees or agents of the institution
- entering into contracts/agreements with an in-state institution or in-state entity to provide services for students (i.e. library, gym, computer centers, etc.)
- requiring a student to take a proctored exam at a location or with an entity in the state selected by the institution
- advertising in local media sources viewed by residents of the state
- hiring online faculty who live in the state
- employing mentors, tutors, or preceptors in the state to aid individual students who are residents of the state
- Courses offered by instructors not residing in Mississippi cannot include face-to-face meetings with students in those other states.
- The way in which physical presence is defined is different based on the state and would need to be considered in any state in which an institution is authorized so as to abide by the physical presence limitations.
- Institutional participants to NC-SARA have specific physical presence considerations that must be considered, which are further specified in the NC-SARA section of this page.
If physical presence is triggered, the institution must become authorized in that state.
*State physical presence triggers apply if an institution that is an NC-SARA member exceeds their permitted physical presence in a state based on the NC-SARA guidelines (see NC-SARA paragraph below).
- If the activities of an institution do not create a “physical presence”, an exception
may apply allowing the institution to provide education to students in the state without
becoming authorized with the state based on their lack of physical presence.
- The following list represent the types of scenarios that create exceptions, though
exceptions vary on a state-by-state basis:
- Religious organizations
- Organizations accredited by an agency approved by the Department of Education
- Non-degree granting programs
- The following list represent the types of scenarios that create exceptions, though exceptions vary on a state-by-state basis:
- Please review the list of states below for more information concerning the University of Southern Mississippi’s compliance with this regulation and to obtain the contact information for the appropriate agency in the state where you reside.
- We are evaluating and working to comply with the various requirements and are updating this page as additional information is received.
Although the University will make reasonable efforts to place admitted students in field experiences and internships, it will be up to the host facility to determine whether a student will be allowed to work at that facility. Students should further be aware that a criminal record may jeopardize licensure by the state certification body. Students may consult the certification body corresponding to their intended occupation for more details. Successful completion of a program of study at the University of Southern Mississippi does not guarantee licensure, certification or employment in the relevant occupation.
NOTE: Certain states have specific requirements before internships can take place within their state. For more information about such requirements, see the State Specific Internship Laws webpage.
The Southern Association of Colleges and Schools Commission on Colleges accredits
The University of Southern Mississippi ("USM") thereby enabling USM to award baccalaureate,
masters, specialist, and doctorate degrees. Please note NC-SARA does not provide reciprocity
for state professional licensing requirements. Contact the Commission on Colleges
for questions about the accreditation of the University of Southern Mississippi:By
Mail- 1866 Southern Lane, Decatur, Georgia 30033-4097 or
If you have a complaint or want to review the options for filing a complaint, please see the following web page:
We highly recommend that students contact the applicable licensure board(s) in their state of residence or in the state where they intend to obtain a license before beginning an academic program that results in licensure.
For information and guidance on out-of-state professional licensure, please visit the Professional Licensure Disclosures page.
For questions regarding State Authorization, email stateauthorizationsFREEMississippi
For questions regarding Professional Licensure, email professionallicensureFREEMississippi
For more information about NC-SARA click the logo below.