NC-SARA Distance Education Compliance

Online education is referred to in various ways.  The two most common ways to categorize online classes are:

1. The percentage of in the classroom “seat time” that is replaced with online course work
   1. A web-enhanced course is a class which has the same frequency and amount of in-person classroom meeting times. Seat time is not replaced but components of the course will be accessible 24/7 through the University's Learning Management System.
   2. A hybrid course is typically a course where some, but not all, of class meeting times are replaced by course delivery through distance learning, also referred to as “blended,” or “multi-mode” course.  
   3. A fully online (distance education) class is one where all the content (including assignments and exams) are delivered online.
       
2. Whether online (distance learning) work is conducted primarily in an asynchronous or synchronous modality.
   1. Synchronous delivery is defined where students access content and non-face-to-face course activities occur at regular specific predetermined scheduled times. The scheduled meetings usually take place via a web conferencing system (WebEx).
   2. Asynchronous delivery is one in which the student accesses and completes instructional material and activities within a scheduled time frame but with no required synchronous meeting times.

Definitions:

Web-enhanced courses meet with the same frequency and amount of in-person classroom meeting times. Seat time is not replaced but components of the course will be accessible 24/7 through the University's Learning Management System (LMS). The amount of online activities will vary depending on the professor and course requirements.

100% of class meeting times are in-person at the scheduled time and location.

Hybrid courses are courses where some, but not all in-person classroom meeting times are replaced by course delivery online. These courses may also be referred to as “blended” or “multi-mode” courses. Designed to take advantage of the best features of face-to-face and online activities.

At least 30% of in-person classroom meeting times are replaced with online course activities. Individual departments may have different guidelines.

Online courses are courses where all content (including assignments and exams) is delivered online. Online course may be synchronous or asynchronous in format. There are no required on-campus sessions.  If an online course requires regular synchronous meetings, those times will be noted in the class schedule.

100% of class meeting times are replaced with online course activities. In an online course that comprises both a lecture and a lab section, the lecture including the lab and exams are undertaken solely online.

Guidelines for Credit Hours and Mode of Instruction

The following guidelines come from the New York State Education Department which defines one semester credit hour as at least 15 hours (of 50 minutes each) of instruction and at least 30 hours of supplementary assignments. [1]

The following table is meant to serve as a guideline for faculty to determine if their online or hybrid course has an appropriate amount of instruction material. The guidelines are meant to be informative and a reference tool for faculty. Just as in an on-ground course, faculty will not be expected to calculate the amount of time students will spend in their online course.

Number of instructional hours offered relative to credit hours and mode of instruction. 

Credit hours        100% Online Instruction                                     Hybrid – At least 30% of Online Instruction
1                            750 mins                                                              At least 225 mins
2                            1,500 mins                                                           At least 450 mins
3                            2,250 mins*                                                         At least 675 mins
4                            3,000 mins                                                           At least 900 mins

[1] Codes, Rules and Regulations of the State of New York, Title 8 – Education Department, Chapter II –Regulations of the Commissioner, Subchapter A – Higher and Professional Regulations, Part 50 – General, Section 50.1.

* To fulfill the 2,250 minute requirement, a typical 3 credit hour course meet either three times per week for 50 minutes or two times per week for 75 minutes.

Policy Statement

D’Youville University is committed to maintaining transparency regarding all student charges, including any costs related to the verification of student identity for students enrolling in distance education. In accordance with federal regulation 34 CFR 602.17(h) and the requirements of the Higher Learning Commission (HLC), the University will notify students in writing of any projected additional charges associated with the verification of student identity at the time of registration or enrollment.

Purpose

The purpose of this policy is to ensure compliance with federal and accreditation requirements and to provide students with clear, timely, and accurate information regarding any fees that may be incurred for identity verification processes required for participation in distance courses.

Scope

This policy applies to all D’Youville University programs that:

• Offer distance education courses or programs,

It covers all students enrolling in such programs, regardless of whether they are degree-seeking, non-degree seeking, or visiting students.

Definitions

Distance Education: Education that uses one or more technologies to deliver instruction to students who are separated from the instructor.

Verification of Student Identity: A process used to confirm that the student who registers for a distance course is the same student who participates in, completes, and receives credit for the course. Methods may include, but are not limited to:

• Secure login and password
• Proctored examinations
• Biometric authentication
• Third-party identity verification services

Responsibilities

Office of the Registrar:

• Ensures written notification of any projected identity verification charges is provided to students at the time of registration or enrollment.
• Maintains updated information on all applicable fees.

Online Learning/Distance Education Office:

• Identifies any technologies or services used for student identity verification that may incur additional charges.
• Communicates fee changes to the Registrar and relevant academic units.

Student Accounts/Bursar:

• Ensures charges are accurately reflected on billing statements.
• Provides clear explanations of fees associated with identity verification.

Notification Procedures

1. Written Notification at the time of Registration/Enrollment:
   • All students enrolling in distance education will receive written notice of any projected additional student charges associated with identity verification. Notification may be delivered via:
     • Student Planning registration site
     • Enrollment confirmation emails
     • Tuition and fee schedules posted on the University website
2. Clear Disclosure:
   • Notices will clearly identify the purpose of the fee, the verification service or method used, and whether the fee is one-time or recurring.
3. Fee Updates:
   • Any changes to identity verification charges must be updated promptly on all student-facing platforms and disclosed prior to the next registration period.

Examples of Potential Charges

Examples of charges that may be associated with identity verification include:

• Proctored exam fees (in-person or virtual)
• Fees charged by third-party online proctoring services
• Fees associated with biometric or secure authentication technologies

If no such charges apply for a given program or semester, students will be notified that no additional fees are projected.

Compliance and Review

This policy will be reviewed annually by the Office of Academic Affairs, the Registrar, and the Distance Education Office to ensure compliance with federal regulations and accreditor requirements.

Non-compliance with this policy may result in findings during accreditation review or federal compliance audits.

Effective Date

This policy becomes effective immediately upon approval and remains in effect until amended or rescinded.

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Policy Statement

D’Youville University is committed to maintaining compliance with applicable federal and state regulations governing distance education, including requirements established by the National Council for State Authorization Reciprocity Agreements (NC-SARA), the New York State Education Department (NYSED), and the Middle States Commission on Higher Education (MSCHE).

Consistent with MSCHE standards for institutional integrity, oversight, and planning, the University establishes this policy to ensure accurate determination, disclosure, and monitoring of student physical location for all students enrolled in distance education offerings.

Purpose

The purpose of this policy is to:

• Ensure that D’Youville University offers distance education only in jurisdictions where the institution is authorized to operate; 
• Ensure accurate identification and tracking of student physical location for regulatory compliance; 
• Support timely licensure disclosures and consumer protection requirements; 
• Maintain compliance with NC-SARA, NYSED, MSCHE, and federal Title IV regulations; 
• Establish clear institutional responsibility for state authorization compliance and reporting. 

Scope

This policy applies to:

• All prospective students at the time of application 
• All enrolled undergraduate, graduate, and professional students 
• All distance education courses, programs, and instructional modalities 
• All experiential, clinical, fieldwork, practicum, or internship activities associated with academic programs 

Definitions

Distance Education: Instruction delivered through electronic or other technologies in which the student and instructor are separated by time, place, or both.

Student Physical Location: The state, territory, or jurisdiction where a student is physically located while engaged in instructional or academic activity, including coursework and experiential learning.

NC-SARA: The National Council for State Authorization Reciprocity Agreements governing interstate delivery of distance education among participating states.

State Authorization: Formal institutional approval required to offer postsecondary education to students physically located in a specific state or jurisdiction.

Institutional System of Record: The official institutional student information system (Banner) maintained by the Registrar, which serves as the authoritative record of student physical location.

Policy Provisions

1. Determination and Recording of Student Location

At the time of application and enrollment, students must provide accurate information regarding their physical location.

The Registrar serves as the official institutional system of record for student physical location data.

D'Youville University uses student-reported information, supported by institutional records, to determine student location for regulatory compliance purposes.

Students are informed that accurate reporting of physical location is required to ensure institutional compliance with state authorization and licensure disclosure obligations.

2. Ongoing Monitoring and Institutional Oversight

Consistent with MSCHE standards for institutional effectiveness, D’Youville University maintains administrative processes to monitor student physical location.

The institution may use administrative records, including mailing addresses, enrollment data, learning management system activity, and experiential learning placement sites, to verify and update student location information.

Any change in student location will trigger institutional review to determine whether:

• State authorization status is affected 
• Professional licensure disclosures require updating 
• Academic delivery or enrollment conditions require adjustment 

3. Change in Student Physical Location

Students are required to update their physical location information within 10–14 calendar days of any change or at the time of registration for each academic term, whichever occurs first.

A change in student location may affect the University’s ability to continue offering instruction in compliance with applicable state authorization requirements.

Where a location change impacts institutional authorization status, the University will determine appropriate academic and administrative actions in accordance with regulatory requirements and institutional policy.

4. State Authorization Compliance

D'Youville University offers distance education only in states and jurisdictions where the institution is authorized to operate through NC-SARA participation or, when required, through separate state authorization.

D’Youville University is solely responsible for determining where it is authorized to provide distance education and makes all final determinations regarding institutional authorization status in each jurisdiction.

If a student’s physical location changes to a jurisdiction where the University is not authorized to provide instruction, the institution will evaluate available options in accordance with regulatory requirements and institutional policy. This may include, but is not limited to, teach-out arrangements, alternative academic pathways, or adjustments to enrollment and course delivery.

If the University’s authorization status changes in a jurisdiction where a student is actively enrolled, the University will determine appropriate academic options to support student progression in compliance with applicable regulatory requirements.

5. Experiential Learning and Clinical Placement Location

For programs that require clinical, fieldwork, practicum, internship, or other experiential learning components, the placement site's location is also considered part of the student's physical location for regulatory reporting purposes.

Academic programs must report experiential learning site locations to the Office of Institutional Research and Effectiveness or designated compliance office for monitoring and reporting purposes.

6. Professional Licensure and Certification Programs

In accordance with federal and state requirements, D’Youville University provides program-specific disclosures regarding whether academic programs meet educational requirements for professional licensure or certification in specific jurisdictions.

Licensure eligibility is determined solely by state licensing boards. Completion of an academic program does not guarantee licensure, certification, or authorization to practice in any jurisdiction.

7. International Student Location

For students outside the United States, the University will evaluate enrollment eligibility and instructional delivery in accordance with applicable international regulatory requirements, institutional authorization capacity, and program delivery feasibility.

8. Student Complaints and Consumer Protection

D’Youville University maintains institutional complaint resolution procedures for all students enrolled in distance education programs.

Complaints must first be resolved through institutional processes. If a complaint is not resolved at the institutional level and falls within NC-SARA jurisdiction, students may submit an appeal to the New York State SARA State Portal Entity, which retains final authority to resolve SARA-eligible complaints.

Roles and Responsibilities

Students

• Provide accurate and complete physical location information at enrollment 
• Update location information within required timeframes (10–14 days or term registration, whichever occurs first) 
• Notify the University of any changes in physical location during enrollment 

Registrar

• Maintains official student physical location records in Banner 
• Ensures accuracy and integrity of location data 
• Supports institutional reporting and compliance monitoring 

Academic and Administrative Units

• Ensure compliance with state authorization and licensure disclosure requirements. 
• Reports experiential learning placement locations 
• Coordinate updates when student location changes impact program delivery 

University Administration / Compliance Office

• Determines institutional authorization status 
• Reviews student location changes for compliance impact 
• Ensures alignment with NC-SARA, NYSED, MSCHE, and federal regulations 

Compliance and Institutional Action

Failure to maintain accurate student physical location information may result in institutional actions necessary to ensure compliance with state authorization and regulatory requirements.

All actions taken are based on institutional authorization obligations and are designed to ensure continued compliance with federal, state, and NC-SARA requirements.

Policy Review

This policy will be reviewed at least every three years, or more frequently if required due to changes in federal regulations, NC-SARA policy updates, NYSED requirements, or MSCHE accreditation standards.

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1. Purpose

D’Youville University is committed to transparency, consumer protection, and compliance with the National Council for State Authorization Reciprocity Agreements (NC-SARA). This policy establishes requirements and procedures for public and direct disclosures to prospective and enrolled students participating in distance education activities, ensuring that students receive accurate, timely, and accessible information necessary for informed decision-making.

2. Scope

This policy applies to:

• All distance education programs, including fully online and hybrid programs
• All credit-bearing courses and programs offered to students residing outside New York State
• All university personnel responsible for academic programs, marketing, admissions, enrollment management, advising, and compliance

3. Definitions

• NC-SARA: National Council for State Authorization Reciprocity Agreements
• Public Disclosure: Information made publicly available to all students and stakeholders via the University’s website or other broadly accessible platforms
• Direct Disclosure: Information provided individually to students at the time required by NC-SARA, typically prior to enrollment or upon a triggering event
• Distance Education: Instruction delivered when students and instructors are separated by time and/or location and interact via electronic means

4. Public Disclosure Requirements

D’Youville University shall make the following information publicly available and easily accessible on its website:

4.1 NC-SARA Membership

• Confirmation that D’Youville University is approved to participate in NC-SARA
• Identification of the University’s home state (New York)

4.2 Complaint Resolution Process

• A description of the University’s internal student complaint process, including contact information and procedural steps
• Notification that unresolved complaints related to distance education may be submitted to the New York State Education Department
• Information on the NC-SARA complaint process, including eligibility criteria and timelines

4.3 Professional Licensure Disclosures

For programs leading to professional licensure or certification:

• General information regarding whether the program meets, does not meet, or has not been determined to meet educational requirements for licensure in states where students may reside
• A statement encouraging students to verify licensure requirements in their state

4.4 Program Availability

• Identification of programs that are available to students in SARA member states, subject to state authorization and professional licensure requirements

5. Direct Disclosure Requirements

D’Youville University shall provide direct, individualized disclosures to students in the following circumstances:

5.1 Professional Licensure Programs

Prior to enrollment or as soon as practicable:

• Written notification to prospective students if a program does not meet educational requirements for licensure in the student’s state of residence
• Notification if the University has not made a determination regarding licensure eligibility in that state

5.2 Adverse Actions

Prompt written notification to affected students if:

• A program loses authorization or approval in a student’s state
• A program ceases to meet licensure requirements in a student’s state
• The University can no longer offer distance education in a particular state

5.3 Delivery Method

Direct disclosures shall be provided through:

• Email to the student’s official University email address, or
• Other verifiable written communication methods that ensure receipt

6. Accuracy and Timeliness

• All disclosures must be current, accurate, and reviewed regularly
• Changes affecting disclosures must be communicated as soon as practicable
• The University will review disclosure content at least annually, or more frequently as required by regulatory changes

7. Roles and Responsibilities

• Provost / Academic Affairs: Oversight of academic program compliance
• Compliance / Accreditation Office: Monitoring NC-SARA requirements and state authorization issues
• Admissions and Enrollment Management: Ensuring disclosures are provided prior to enrollment
• Program Directors: Verifying professional licensure information and reporting changes

8. Recordkeeping

D’Youville University shall maintain records of:

• Public disclosures posted on the University website
• Direct disclosures provided to students
• Licensure determinations and related communications

Records will be retained in accordance with University record retention policies and regulatory requirements.

9. Non-Compliance

Failure to comply with this policy may result in:

• Institutional risk to NC-SARA participation
• Regulatory findings or sanctions
• Corrective actions as determined by University leadership

10. Policy Review

This policy shall be reviewed:

• Annually, and
• Upon changes to NC-SARA requirements or applicable state or federal regulations

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