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 all 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, planning, and oversight, the University establishes this policy to ensure accurate determination, disclosure, and monitoring of student location for 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 it is authorized to do so;
• Promote transparency and consumer protection for students, consistent with NYSED and MSCHE expectations;
• Support institutional planning, compliance monitoring, and risk management related to distance education.

Scope

This policy applies to all distance education courses and programs offered by D’Youville University and to all students enrolled in such offerings, regardless of residency status or academic level.

Definitions

• Distance Education: Instruction delivered through electronic or other technologies in which the student and instructor are separated by time, place, or both.
• Student Location: The physical location (state, territory, or international jurisdiction) in which a student is located while engaging in distance education activities.
• NC-SARA: The interstate agreement that establishes a framework for authorization of distance education across participating states.
• State Authorization: Formal approval required by a state or jurisdiction for an institution to offer postsecondary education to students located within that jurisdiction.

Policy Provisions

1. Determination and Disclosure of Student Location

At the time of application and enrollment, students must provide accurate information regarding their physical location. D’Youville University relies on student-reported location data as the primary basis for determining state authorization requirements, consistent with NC-SARA guidance and NYSED expectations.

The University clearly discloses to students the importance of accurate location information and the potential academic and regulatory implications of enrollment in distance education programs based on location.

2. Ongoing Monitoring and Institutional Oversight

Consistent with MSCHE standards for institutional effectiveness and oversight, D’Youville University maintains administrative processes to monitor student location for compliance purposes. The University may use institutional records, including but not limited to mailing addresses or other administrative data, to support compliance monitoring.

3. Change in Student Location

Students enrolled in distance education courses or programs are responsible for notifying the University in a timely manner of any change in their physical location. A change in student location may affect the University’s authorization to offer instruction and may result in limitations on continued enrollment, course participation, or program progression until compliance can be assured.

4. State Authorization Compliance

D’Youville University offers distance education only in states and jurisdictions where it is authorized to do so through NC-SARA participation or through separate state authorization when required. If a student relocates to a jurisdiction in which the University is not authorized, the University will take appropriate action consistent with regulatory requirements and institutional policy.

5. Professional Licensure and Certification Programs

In accordance with NYSED and federal disclosure requirements, D’Youville University provides information regarding whether academic programs leading to professional licensure or certification meet educational requirements in specific states. Students are responsible for determining licensure eligibility in the jurisdiction where they intend to seek licensure. The University does not guarantee licensure or certification outside of identified jurisdictions.

6. Student Complaints and Consumer Protection

Consistent with NC-SARA, MSCHE, and NYSED consumer protection standards, D’Youville University maintains internal procedures for resolving student complaints related to distance education. Students residing outside New York State who are unable to resolve a complaint through institutional processes may submit complaints to the New York State Education Department or through the NC-SARA complaint resolution process, as applicable.

Roles and Responsibilities

• Students: Provide accurate and timely information regarding physical location and notify the University of changes.
• Academic and Administrative Units: Ensure distance education offerings comply with applicable authorization and disclosure requirements.
• University Administration: Maintain oversight of state authorization compliance and ensure alignment with MSCHE standards and NYSED regulations.

Compliance and Enforcement

Failure to comply with this policy may result in administrative action, including restrictions on enrollment or participation in distance education offerings, consistent with institutional procedures and regulatory requirements.

Policy Review

This policy will be reviewed on a regular cycle to ensure continued alignment with NC-SARA standards, NYSED regulations, and MSCHE accreditation expectations.

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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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