State Authorization FAQs

States may require out-of-state institutions to obtain authorization to offer postsecondary education in accordance with its laws and regulations. State regulations vary from minimal to very strict requirements. In the majority of states, the need to seek authorization depends on the specific combination of that state’s laws and the activities an institution is conducting in that state. Those activities derive from how the state defines “operating,” “physically located,” or “physical presence.”

Each state statute defines “operating,” “physically located,” or “physical presence” differently, including, but not limited to:

Russell Sage College must comply with all regulations and receive authorization from a state before allowing students to participate in any educational activities through the College. While these regulations initially applied only to online education, it now applies to courses in campus-based programs that include internships, co-ops, student teaching, clinical placements, and/or field experiences occurring in states outside of New York. Conducting state authorization analysis is necessary anytime a student is engaging in educational activities outside of the State of New York.

States expect that institutions obtain approval before enrolling students, advertising, marketing, or performing other regulated activities in their state. The requirements as to which activities need authorization, the application processes, and the costs to comply vary greatly from state to state.

The State Authorization Reciprocity Agreement (SARA) established uniform standards for physical presence. New York became a SARA state in 2017, and Russell Sage College became a SARA institution in March 2017. Through reciprocity, an institution authorized under SARA in its home state would be considered authorized in all other SARA states.