National Council for State Authorization Reciprocity Agreements - May 4-5, 2021 Virtual Meeting - NC-SARA
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
National Council for State Authorization
Reciprocity Agreements
NC-SARA Board Meeting
Virtual Meeting
May 4-5, 2021
3005 Center Green Drive Suite 130 ● Boulder, CO 80301 ●
303.848.3764 ● www.nc-sara.org
Page 1 of 34
Table of Contents
AGENDA ....................................................................................................................................... 2
NC-SARA Board Members ........................................................................................................... 3
NC-SARA Staff ............................................................................................................................. .7
Regional Compact Staff–SARA Directors And Coordinators ..................................................... .8
NC-SARA Consultants and Guests............................................................................................... 9
Agenda Item I: Approval of Minutes of the October 28-29, 2020 Meeting .............................. 11
Agenda Item II: Update on NC-SARA Progress ........................................................................ 24
Agenda Item III: Update from Regional Compacts on SARA ................................................... 25
Agenda Item IV (ACTION): Report and recommendations for the Executive Committee....... 26
Agenda Item V (ACTION): Finance Committee report ............................................................. 27
Agenda Item VI (ACTION): Federal Higher Education Landscape Impact on NC-SARA ......... 28
Agenda Item VII: Update on 21st Century Distance Education Guidelines .............................. 29
Agenda Item VIII: Branch Campus Working Group ................................................................. 30
Agenda Item IX (ACTION): Modifications to the SARA Policy Manual ...................................... 31
Agenda Item VII (ACTION): Executive session ......................................................................... 49
Agenda Item VIII (ACTION): Questions, comments, reflections from board members .......... 49
Appendix A: Staff Meetings and Presentations ....................................................................... 50
Appendix B: Report from the NC-SARA Branch Campus Working Group to the NC-SARA
Board …………………………………………………………………………………………………………………..55
Appendix C: Proposed 21st Century Distance Education Guidelines……………………………….83
2
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
AGENDA
Welcome and introductions – Teresa Lubbers, Chair
Agenda Item I (ACTION): Approval of minutes of the October 27-29, 2020 meeting
Agenda Item II: Update on NC-SARA progress – Lori Williams and staff
Agenda Item III: Update from Regional Compacts on SARA
a) Susan Heegaard, Midwestern Higher Education Compact (MHEC)
b) Michael Thomas, New England Board of Higher Education (NEBHE)
c) Stephen Pruitt, Southern Regional Education Board (SREB)
d) Demarée Michelau, Western Interstate Commission for Higher Education
(WICHE)
Agenda Item IV (ACTION): Report and recommendations of the Executive Committee –
Teresa Lubbers, Chair
Agenda Item V: (ACTION): Finance Committee Report – Leroy Wade, Treasurer
Agenda Item VI: Federal Higher Education Landscape Impact on NC-SARA – Catherine
Guttman-McCabe
Agenda Item VII: Update on 21st Century Distance Education Guidelines – Sally Johnstone
& Barbara Brittingham
Agenda Item VIII: Branch Campus Working Group – Belle Wheelan & Susan Heegaard
Agenda Item IX: (ACTION): Modifications to the SARA Policy Manual
Agenda Item X (ACTION): Executive session
Agenda Item XI: Questions, comments, reflections from Board members
Adjourn
3
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
NC-SARA Board Members
Please note that the current term for each Board member ends after the final board
meeting of the specified year next to each name. Compact presidents are not term
limited.
Rob Anderson – 2022 Art Coleman – 2022
President Managing Partner and Cofounder
State Higher Education Executive Education Counsel, LLC
Officers Association 101 Constitution Ave NW Suite 900
3035 Center Green Drive Suite100 Washington, DC 20001
Boulder, CO 80301 202.689.2961
303.541.1605 art.coleman@educationcounsel.com
randerson@sheeo.org
Laurie Dodge – 2022
Barbara Ballard – 2021 Vice Chancellor of Institutional
State Representative Kansas Assessment and Planning and Vice
Legislature Provost
Dole Institute at the University of Brandman University
Kansas 16355 Laguna Canyon Road
2350 Petefish Drive Irvine, CA 92618
Lawrence, KS 66045 949.341.9813
785.864.4900 ldodge@brandman.edu
*Chris Bustamante – 2022 Lanna Dueck – 2023
Executive Director, Arizona Community Executive Director
College Coordinating Council Arizona SARA Council
Rio Salado College 2323 W. 14th Street
11617 South 71st Street Tempe, AZ 85284
Tempe, AZ 85284 480.517.9229
602.320.3297 ldueck.azsara@riosalado.edu
bustamanterio1@gmail.com
*Susan G. Heegaard – Continuing
John Cavanaugh – 2022 President
Former President and CEO (Retired) Midwestern Higher Education
Consortium of Universities of the Compact Fifth Avenue South, Suite
Washington Metropolitan Area 450 Minneapolis, MN 55401
291 Abercorn Circle 612.677.2761
Chapel Hill, NC 27516202.331.8080 susanh@mhec.org
globaljcc@gmail.com
4
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
Angela Lee – 2023 Carlos Morales – 2023
Executive Director of the District of Columbia President Tarrant County Colleges
Higher Education Licensure Commission Connect Campus
1050 First Street, NE, 444 N. Henderson Street
Washington, DC 20002 Ft. Worth, Texas 76102
202.412.4705 817.515.8002
angela.lee@dc.gov carlos.morales@tccd.edu
*°Teresa Lubbers – 2021 *Stephen Pruitt – Continuing
Chair President
Commissioner Southern Regional Education Board
Indiana Commission for Higher Education 592 10th Street Northwest
101 West Ohio Street, Suite 300 Atlanta, GA 30318
Indianapolis, IN 46204 404.875.9211
317.464.4400 stephen.pruitt@sreb.org
tlubbers@che.in.gov
Pamela “Pam” Quinn – 2022
°Leah K. Matthews – 2021 Vice President for Academic Affairs
Executive Director (Interim) Tarrant County College-
Distance Education Accrediting Commission Connect Campus
1101 17th Street Northwest, Suite 808 LeCroy Center
Washington, D.C. 20036 Dallas County Community College
202.234.5100, ext.101 District
leah.matthews@deac.org 1213 Chapel Hill Court
McKinney, TX 75069
°Demarée “Demi” Michelau – Continuing 214.957.8750
President pamquinn@icloud.com
Western Interstate Commission for Higher
Education *Edward “Ed” Ray – 2021
3035 Center Green Drive, Suite 200 Vice Chair
Boulder, CO 80301 President (Retired)
303.541.0121 Oregon State University Office of the
dmichelau@wiche.edu President
600 Kerr Administrative Building
°Patricia “Pat” O’Brien – 2022 Corvallis, OR 97331
Senior Vice President of the Commission 541.737.4133
New England Commission of Higher Education ed.ray@oregonstate.edu
3 Burlington Woods, Suite 100
Burlington, MA 01803
781.425.7712
pobrien@neche.org
5
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
°George E. Ross – 2021 *Larry Tremblay – 2023
President Emeritus Deputy Commissioner
Central Michigan University Planning Research and Academic
125 Somerset Hill Affairs (Retired)
McDonough, GA 30253 Louisiana Board of Regents
989.854.6234 2221 Hood Avenue
ross14ge@cmich.edu Baton Rouge, LA 70808
225.343.7684
Paul Shiffman – 2022 ltremb1948@gmail.com
Chief Executive Officer
Presidents’ Forum at Excelsior College *°Leroy Wade – 2022
(Retired) Treasurer
201 Burwick Road Deputy Commissioner
Highland Heights, OH 44143 Missouri Department of Higher
440.683.1355 Education and Workforce
pshiffman@excelsior.edu Development
P.O. Box 1469
Peter Smith – 2023 Jefferson City, MO 65102
Orkand Chair and Professor of Innovative 573.751.2361
Practices in Higher Education leroy.wade@dhewd.mo.gov
University of Maryland Global Campus
2022 Foothills Road Belle Wheelan – 2021
Santa Fe, NM 87505 President
954.218.0184 Southern Association of Colleges
peter.smith@umuc.edu and Schools Commission on
Colleges
Michael Thomas – Continuing 1866 Southern Lane
President and Chief Executive Officer New Decatur, GA 30033
England Board of Higher Education 45 404.679.4512
Tempe Place bwheelan@sacscoc.org
Boston, MA 02111
617.357.9620, ext. 119 *Member of the NC-SARA
mthomas@nebhe.org Executive Committee
°Member of the NC-SARA Finance
Committee
6
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
NC-SARA Staff
Staff Address:
National Council for State Authorization Reciprocity Agreements
3005 Center Green Drive, Suite 130
Boulder, CO 80301
Ray Audett Holly Martinez
Associate Director for Accounting Technician and
Technical Operations CustomerSupport Specialist
303.848.3278 303.848.3275
raudett@nc-sara.org hmartinez@nc-sara.org
Marianne Boeke Nick Ortiz
Senior Director for Research and State Student and Institution Support
Support Technical Specialist
303.242.5037 303.242.5036
mboeke@nc-sara.org nortiz@nc-sara.org
Melanie Booth Yovani Pina
Director for Educational Programs Director – Information Technology
and Communications 970.200.8409
720.684.5854 ypina@nc-sara.org
mbooth@nc-sara.org
Jessica Prihoda
Lauren Brunell Administrative Assistant
Executive Assistant 303.848.3764
303.848.3764 jprihoda@nc-sara.org
lbrunell@nc-sara.org
Shannon Walker
Rachel Christeson Associate Director for BusinessOperations
Assistant Director for Research Human Resources303.242.5038
and Data Analysis swalker@nc-sara.org
720.600.2354
rchristeson@nc-sara.org Lori Williams
President and Chief Executive Officer
Mary Agnes Larson 303.848.3283
Executive Director for Student lwilliams@nc-sara.org
and Institution Support
303.848.3288 Jeannie Yockey-Fine
mlarson@nc-sara.org General Counsel
303.647.5055
jyockey-fine@nc-sara.org
7
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
Regional Compact Staff–SARA Directors And Coordinators
Midwestern Higher Education Compact - MHEC Southern Regional Educational Board – SREB
Emily Jacobson Wanda Barker
Manager, M-SARA Director, S-SARA
Midwestern Higher Education Compact Division Director of Education Technologies
105 Fifth Avenue, Suite 450 and Multi-State Cooperative Programs
Minneapolis, MN 55401 Southern Regional Education Board 592
612.677.2771 10th Street Northwest
emilyj@mhec.org Atlanta, GA 30318
404.875.9211, ext.258
Leah Reinert wanda.barker@sreb.org
Policy and Research Manager
Midwestern Higher Education Compact Elisa Jaden
105 Fifth Avenue, Suite 450 Coordinator, S-SARA
Minneapolis, MN 55401 Student Access Programs and Services
612-677-2775 Southern Regional Education Board 592
leahr@mhec.org 10th Street Northwest
Atlanta, GA 30318
New England Board of Higher Education 404.875.9211, ext. 217
– NEBHE elisa.jaden@sreb.org
Sheridan Miller Western Interstate Commission for
Policy & Research Analyst/SARA Coordinator Higher Education – WICHE
New England Board of HigherEducation
45 Tempe Place Shelley Pluto
Boston, MA 02111 Administrative Assistant III, W-SARA
617.533.5924 Western Interstate Commission for Higher
smiller@nebhe.org Education
3035 Center Green Drive, Suite 200
Rachael Stachowiak Boulder, CO 80301
Associate Director, N-SARA 303.541.0317
New England Board of HigherEducation splutto@wiche.edu
45 Tempe Place
Boston, MA 02111 Christina Sedney
617.533.9503 Director of Policy Initiatives and State
rstachowiak@nebhe.org Authorization, W-SARA
Western Interstate Commission for Higher
Education
3035 Center Green Drive, Suite 200
Boulder, CO 80301
303.541.0238
csedney@wiche.edu
8
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
NC-SARA Consultants and Guests
Alan Contreras
Consultant
3895 Kevington Avenue
Eugene, OR 97405
acontrer56@gmail.com
Catherine R. Guttman-McCabe
Partner
Potomac Law Group, PLLC
1300 Pennsylvania Avenue, NW, Suite 700
Washington, D.C. 20004
(202) 262-7083
cguttman-mccabe@potomaclaw.com
Barbara Brittingham
NCHEMS Consultant
3035 Center Green Dr
Suite 150
Boulder, CO 80303
(303) 497-0301
BBrittingham@neche.org
Sally Johnstone
NCHEMS Consultant
3035 Center Green Dr
Suite 150
Boulder, CO 80303
(303) 497-0301
sally@nchems.org
9
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021
Welcome and introductions — Teresa Lubbers, Chair
Action Item: ☐ Yes ☒ No
10
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021NC-SARA AGENDA ITEM
Agenda Item I: Approval of Minutes of the October 28-29, 2020 Meeting
Action Item: ☒ Yes ☐ No
11
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021MINUTES OF THE NC-SARA BOARD MEETING
October 28-29, 2020
VIRTUAL MEETING
DENVER, COLORADO
NOTICE OF MEETING
Notice of the time and place of the NC-SARA Board Meeting was posted on the NC-SARA website
and given to the Board members, regional compact SARA staff, and other interested parties.
An agenda is maintained in the NC-SARA office at 3005 Center Green Drive, Suite 130, Boulder,
Colorado, 80301 and online at www.nc-sara.org.
Welcome and introduction: Teresa Lubbers, Chair
Board members in attendance:
Rob Anderson Demarée Michelau
Barbara Ballard Stephen Pruitt
Chris Bustamante Pamela Quinn
John Cavanaugh Edward Ray
Art Coleman George Ross
Kathryn Dodge Paul Shiffman
Laurie Dodge Peter Smith
Dianne Harrison Michael Thomas
Susan Heegaard Larry Tremblay
Paul Lingenfelter Leroy Wade
Teresa Lubbers Belle Wheelan
Leah Matthews
NC-SARA staff present:
Raymond Audett Nick Ortiz
Marianne Boeke Richard Parker
Melanie Booth Jessica Prihoda
Lauren Brunell Shannon Walker
Rachel Christeson Lori Williams
Mary Larson Jeannie Yockey-Fine
Holly Martinez
12
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Regional Compact Staff:
Wanda Barker, SREB
Emily Jacobson, MHEC
Elisa Jaden, SREB
Sheridan Miller, NEBHE
Shelley Plutto, WICHE
Christina Sedney, WICHE
Rachael Stachowiak, NEBHE
Guests:
Alan Contreras
Michael “Mike” Goldstein
Catherine R. Guttman-McCabe
13
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021MINUTES OF THE NC-SARA BOARD MEETING
Meeting was called to order at 9:00 AM (Mountain Standard Time)
OCTOBER 28, 2020
Chair Lubbers opened the meeting with a welcome to all and roll call. All board members
reported as present.
Agenda Item I (ACTION): Approval of minutes of the May 6, 2019 meeting
Motion to approve – Ed Ray
Seconded – John Cavanaugh
Following a friendly amendment from Michael Thomas to correct the minutes to show
Rachael Stachowiak works for NEBHE and not WICHE, the approval passed
unanimously.
Agenda Item II: Update on NC-SARA Progress
a) Lori Williams, NC-SARA
NC-SARA President and Chief Executive Officer Lori Williams shared an updateon
the progress made in the first quarter of NC-SARA’s first three-year strategic plan,
with assistance from General Counsel Jeannie Yockey-Fine and Executive Director
for Student and Institution Support, Mary Larson. Jeannie Yockey-Fine shared about
the status of the annual data collection and report, citing a 99% response rate,
during the pandemic, with over 3 million distance education enrollments and nearly
350,000 out of state learning placements.
Assistant Director for Research and Data Analysis, Rachel Christeson gave an update on the
status of the enrollment and experiential learning placement reporting for 2019, as well as an
update on the status of the cost savings study.
Jeannie Yockey-Fine gave a brief update regarding federal regulations impacting NC-SARA.
14
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021President Williams shared a few updates and graphic images representing the value of NC-SARA
and the improvements to consumer protection, and continuedwith some updates on the progress
made on achievement of the goals and objectives in the strategic plan in its first quarter of
implementation.
Williams also shared about the addition of two new staff members, Dr. Melanie Booth, Director of
Educational Programs and Communications, and Dr, Rachel Christeson, Assistant Director for
Research and Data Analysis. She also shared that a new Director of Information Technology,
Yovani Pina is starting with NC- SARA on November 16, 2020 and would be joining the board
meeting to introduce himself the next day. Mary Larson gave an update on the status of
information technology and other programs at NC-SARA including a refresh of the NC-SARA
website to include the new branding, the searchable student program catalog, and the state
authorization guide.
Belle Wheelan and Barbara Ballard complimented Williams on having accomplished so much in a
short period of time.
b) Susan Heegaard, President, Midwestern Higher Education Compact (MHEC)
President Susan Heegaard of MHEC announced the selection of several SARA
State Portal Entity staff, SARA participating institution leaders, and board
members to a board appointed Branch Campus Working Group which will work
between the Fall 2020 and Spring 2021 board meetings on a report to inform
branch campus policy. President Heegaard noted that MHEC includes eleven state
members of SARA, with MHEC sharing North Dakota and South Dakota with
WICHE, and 500 SARA participating institutions. President Heegaard said that
MHEC held its annual meeting in July virtually for its SARA regional steering
committee, with a planned half-day workshop for state portal entities. She also
shared about the difficulty that some institutions have in adhering to the
professional licensure policy in place at NC-SARA since its inception, given the new
federal requirements and NC-SARA board vote to continue this disclosure policy
in the spring of 2020.
15
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021c) Michael Thomas, President, New England Board of Higher Education (NEBHE)
President Michael Thomas of NEBHE shared that NEBHE includes eight state
members of SARA and just under 300 SARA participating institutions. He noted that
since the beginning of the pandemic, 34 institutions from the NEBHE region, about
four per month, joined SARA as participants. He cited this as a demonstration of the
ongoing value and evidence of the dynamic nature of higher education institutions.
President Thomas expressed concern about enrollment declines between 1.5% and
15% across institutions and states totaling an estimated $1.5 billion in lost tuition
revenue. He then thanked the three board members cycling off and wished all good
holidays in spite of the pandemic.
d) Stephen Pruitt, President, Southern Regional Education Board (SREB)
Wanda Barker, SREB Division Director, shared the SREB update on behalf of President
Stephen Pruitt. Ms. Barker shared that SREB includes 16 state members and over
1,100 participating institutions, over 45% of the total SARA participating institutions. Of
the total institutions, 93 are HBCUs, and represent 95% of all HBCUs in the US. Ms.
Barker also reported that four states were renewed as SARA members by the SREB
regional steering committee earlier inthe fall and their chair and vice chair were re-
elected to serve an additional term. She also provided an update on the status of
SREB SARA states appeals process with twelve ready to implement an appeal process
on January 1, 2021, and eight states working to complete creating such a process.
e) Demarée (Demi) Michelau, President, Western Interstate Commission forHigher
Education (WICHE)
President Demarée Michelau expressed appreciation to President Williams for
continued improvement and productivity in spite of the pandemic. President Michelau
said that WICHE has thirteen states and 254 institution and echoed President Thomas’s
gratitude for the continuing openness in the policy review process with positive
feedback from the WICHE region. She shared that Lanna Dueck serves as chair of the
WICHE regional steering committee and there were smooth transitions of members
of that committee. President Michelau explained that WICHE is now holding monthly
SARA steering committee meetings to focus on state relationships, collaborative
discussions, regional issues, and policy development. She also reported that two
states were renewed in June 2020 and that Nevada held a virtual SARA state meeting
in October. President Michelau shared that WICHE received an extension to implement
a compact appeals process and that this is progressing well. Finally, she shared that
there is continued interest from states and territories in the WICHE region to join
SARA, thanking President Williams for continued open communication with interested
16
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021parties in California, including consumer advocates. Chair Lubbers suggested the board
take a thirty-minute break before reconvening to break into discussion groups.
Agenda Item III: Small Group Discussions – Teresa Lubbers, Board Chair
Chair Teresa Lubbers invited board members to break into groups to discuss four topics. She
explained that the purpose of the discussions was to engage board members in topics of interest
and concern to NC-SARA without actions for vote. Each group was asked to elect a spokesperson
to report out on the key takeaways from each discussion.
The topics were:
a) What is the role of NC-SARA in Quality Assurance in Distance Education?
b) How do you see the evolution of governance at NC-SARA?
c) What is the current and future role of the regional steering committees?
d) What should the action be for NC-SARA, post-COVID when accreditor, federal, and state
waivers of distance education regulation expire?
Discussion ensued regarding each topic with staff taking notes for potential future board or staff
action.
The first portion of the meeting adjourned at 1:00 pm Mountain Time
17
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021OCTOBER 29, 2020
Meeting was called to order at 9:00 AM (Mountain Standard Time)
Chair Lubbers opened the meeting with a welcome to all and roll call. All board members
reported as present. In a change to the agenda, she then explained that the Finance Committee
Report would come before the Executive Committee Report.
Agenda Item IV: Finance Committee Report – Leroy Wade, Treasurer
Treasurer Wade directed attention to the fiscal year 2020 financial audit and indicated that the
Finance Committee had no questions or concerns with stable revenue from 2019 to 2020.
Treasurer Wade then asked Director of Finance, Rich Parker, to share additional information
concerning the audit. Mr. Parker said that the audit represents a year of a maturing organization
with no significant or unexpected entries and no comment with feedback sharing process
deficiencies. He also shared that NC-SARA will put out a bid for a new auditor in the coming year
as it is the fifth year with this auditor.
a) (ACTION) NC-SARA FY 2020 Audit
Chair Lubbers called for a motion to approve the fiscal year 2020 financial audit.
Motion to approve – Leroy Wade
Seconded – Kathryn Dodge
Motion carried unanimously with Leroy Wade recusing himself from the vote.
b) Q1 FY 2021 Financial Report
Treasurer Wade reported that the first quarter fiscal year 2020 report reflects a
stable quarter that is on target and with less than 1% variation from planned
budget. He also shared that this quarter shows movement of reserves funds into the
investments planned through implementation of the NC-SARA reserves and
investment policies.
c) Recommendation for the Election of a new Finance Committee Member
Treasurer Wade shared that with Kathryn Dodge cycling off the board, a
replacement is needed on the Finance Committee. He said that the committee
nominates Paul Shiffman given he is not cycling off at the end of 2021 and could
complete a two-year term, is not also on the Executive Committee, and is not a new
board member.
18
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Susan Heegaard raised a concern about Paul Shiffman’s ability to be fair in this capacity given
earlier remarks concerning the need for an audit of the operational structure of NC-SARA including
the role of the regional compacts. Paul Shiffman said he would be fair in his role on the Finance
Committee and Susan Heegaard thanked him. Ed Ray said that in his experience to conduct such an
audit is common practice and that he supports this effort.
Chair Lubbers called for a motion to approve electing Paul Shiffman to the Finance Committee to
replace Kathryn Dodge.
Motion to approve – Leroy Wade
Seconded – Peter Smith
Motion carried unanimously with Leroy Wade recusing himself from the vote.
Agenda Item V: (ACTION): Report and recommendations of the Executive Committee –
Teresa Lubbers, Chair
a) Recommendations for the election of Board members
Chair Lubbers explained that the board would turn to the election of three new board members to
three-year terms from 2021 through 2023. There were over 65 nominations and self-nominations
expressing their deep interest in working with NC-SARA moving forward. She said the Executive
Committee was particularly looking to fill gaps in the areas of state regulation, portal entities
and community college representation. Chair Lubbers also called attention to the fact that five
more board members will cycle off at the end of 2021 and seven cycling off at the end of 2022.
Art Coleman asked about the efforts to add an attorney general, consumer advocates and
students to the board. Discussion about these ideas continued with Lori Williams sharing that she is
working to continue conversations with board members in collaboration with consumer
advocates and the National Association of Attorneys General. She also shared that she is
continuing work on a social media plan to ensure outreach to students through connection with
Higher Learning Advocates. Paul Lingenfelter shared that adding Art Coleman and Rob Anderson
to the board was because of their commitment to student wellbeing and work with the Institute
for Higher Education Policy. He added that the board members have a broad perspective and do
not feel a responsibility to argue a particular point of view, focusing on the welfare of students and
higher education.
19
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Several board members shared words of support for the three nominations. Chair Lubbers called
for a motion to approve electing Angela Lee, Lanna Dueck, and Carlos Morales to the NC-SARA
Board.
Motion to approve – John Cavanaugh
Seconded – Belle Wheelan
Motion carried unanimously.
b) Recommendation of Re-Election of Two Board Members
Following a brief discussion regarding the terms for Peter Smith and Larry Tremblay, Chair
Lubbers called for a motion to approve re-electing Peter Smith and Larry Tremblay to a second
three-year term from 2021 through 2023.
Motion to approve – Barbara Ballard Seconded – Pat O’Brien
Motion carried unanimously and was subsequently withdrawn by Barbara Ballard
and Pat O’Brien for more research and a possible later vote via email.
A unanimous vote to delay was passed. (Following the meeting, it was confirmed
that in fact Peter Smith and Larry Tremblay had been re-elected at the fall 2019
meeting to an additional term that runs through the end of 2022.)
c) Modification of the NC-SARA Bylaws – Catherine Guttman-McCabe
Chair Lubbers invited Catherine Guttman-McCabe to lead the board through a series of less
substantive changes to the NC-SARA board bylaws, and explained that Mike Goldstein would later
lead a subsequent discussion regarding potential bylaws changes.
Catherine Guttman-McCabe began by mentioning a few global changes and notes. She clarified
that “members” as used in the bylaws refers to the board of directors and that there are no
members of the corporation under Colorado law and in the articles of incorporation. Guttman-
McCabe then led the board through explanation of several edits to the bylaws beginning with
Section 1.
There was a recommendation from Belle Wheelan to edit the number of days prior to board
meeting at which new board members would be elected, to show as 14 to share a list of nominees
with the full board. Additional changes included the addition of a Secretary of the Board as
required by Colorado law, procedures for the election of officers, and the power of the executive
committee between meetings.
20
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021A recommendation was made to exclude the phrase “when travel is not possible,” in Article IV,
Section 2, b, entitled Attendance, in order to emphasize the expectation that board members will
attend in person whenever possible.
A friendly amendment was shared to add the word “board” between “NC-SARA” and “members”
in the first sentence in Article VI, Section 1.
Chair Lubbers also called for a friendly amendment to Article VII, Section 1a, to add the phrase
“of the membership” between “two-thirds” and “vote” in the last phrase of the lastsentence.
Chair Lubbers also called for a vote to approve the bylaws changes as amended.
Motion to approve – Stephen Pruitt
Seconded – John Cavanaugh
Motion carried unanimously.
d) Discussion of NC-SARA Bylaws Issues – Mike Goldstein
Discussion began with issues related to the election of board members and officers. There was
general agreement that when possible, it is preferable for board members to have had a year of
experience prior to service as officers. It was also agreed that the Vice Chair assumes the role of
Chair, unless there is reason to believe that Vice Chair will not serve ably, and that this
assumption does not require a change to the bylaws, but represents process. Others suggested a
possible policy statement regarding this practice over including this provision in the bylaws.
Opinions were shared about whether a board member replacing someone leaving earlier than a
full term continues that term and then has additional three-year terms, or not. This issue will
require additional discussion and agreement to clarify this issue in the bylaws.
The next bylaws issues discussed pertained to the Executive Committee. It was agreed that the
rotation schedule for committee appointments of the regional compact presidents would be
shared with the board and additional clarification added to the bylaws at a later date. Clarification
regarding the role of the Finance Committee in working with NC-SARA staff, and the Finance
Director specifically, to identify an auditor was already addressed in the bylaws revisions.
A brief discussion took place regarding the role of the Executive Committee in setting the agenda
for the full board. Goldstein explained that it is common practice for the Executive Committee to
set the board agenda with the President and that board members have the ability to raise issues
at a meeting without going through the Executive Committee. There was also discussion about
how any board member might add new business to the agenda. Finally, Goldstein expressed his
and Catherine Guttman-McCabe’s surprise and concern that the bylaws contain a provision in
Article six, regarding the manner in which the president communicates with the board. He
21
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021strongly recommended deleting this entire section as it represents procedure over policy.
Agenda Item V: (ACTION): Modifications to the SARA Policy Manual
After explaining that there were six proposed modifications for board consideration, discussion
and vote, with the first modification being called for a vote separately from the other five, Chair
Lubbers invited President Williams and her team to explain the rationale for the modifications.
Policy Change Modification
a) (ACTION) Approve Section 3.2 change to add one additional reason that a state might
put an institution on provisional status.
Following a comment from Stephen Pruitt to note that NC-SARA must be clear with states about
what is not negotiable and when states have flexibility, Chair Lubbers called for a motion to
approve.
Motion to approve –Larry Tremblay
Seconded – Leroy Wade
Motion carried unanimously.
Policy Clarification Modifications
b) (ACTION) Approve Section 1 modification to add a phrase regarding non-credit bearing
courses to the definition of “Operate.”
No board discussion followed the explanation for this modification.
c) (ACTION) Approve Section 2.6(c) modification to replace the word “it” with “the
Compact” for clarity of reference.
A friendly amendment was requested by Patricia O’Brien to replace the word “themselves” with
“itself” in the red lined version of the modification. No additional board discussion followed the
explanation for this modification.
d) (ACTION) Approve Section 3.1(b)(6) modification to language to align with application
requirements for all institutions when programs are no longer offered
No board discussion followed the explanation for this modification.
e) (ACTION) Approve Section 4.4(g) modification to delete the word “issues” in the
context of the section regarding mandatory arbitration.
No board discussion followed the explanation for this modification.
22
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021f) (ACTION) Approve Section 8.2(a) modification to add a phrase to specifically indicate
that input on policy is expected from institutions and other key stakeholders and
brought to the attention of NC-SARA.
Following a couple of clarifying questions from Susan Heegaard and Robert Anderson, which were
answered by President Williams, Chair Lubbers called for a motion to approve the five
modifications.
Motion to approve – Robert Anderson
Seconded – Paul Shiffman
Motion carried unanimously.
Agenda Item VI: Executive session
Agenda Item VII: Questions, comments, reflections from Board members
Adjourn
Meeting was adjourned following a private executive session.
23
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item II: Update on NC-SARA Progress
Action Item: ☐ Yes ☒ No
Background: NC-SARA began inviting states to join in early 2014. As of May 2021, 49
states plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands -- are
members. Discussions continue in California. 2,265 institutions participate in SARA as
of April 7, 2021.
Lori Williams will provide an overall assessment. Regional compacts will focus on
SARA developments within their regions.
a) Lori Williams, National Council for State Authorization
Reciprocity Agreements (NC-SARA)
a. Update on Strategic Plan progress
b. Update on Communications Plan and Educational Programming
c. Update on Website Refresh
d. Update on Information Technology
e. Update on Enrollment Data and Cost Savings Study
f. Consumer Protection Update Impacting SARA
g. State Authorization Guide and Professional Licensure Directory
h. SARA Source
i. In the Field NC-SARA Institution Conference
24
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item III: Update from Regional Compacts on SARA
Action Item: ☐ Yes ☒ No
a) Susan Heegaard, Midwestern Higher Education Compact (MHEC)
b) Michael Thomas, New England Board of Higher Education (NEBHE)
c) Stephen Pruitt, Southern Regional Education Board (SREB)
d) Demarée Michelau, Western Interstate Commission for HigherEducation (WICHE)
25
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item IV (ACTION): Report and recommendations for the Executive
Committee – Teresa Lubbers, Chair
Action Item: ☒ Yes ☐ No
a) Update on Policy Review meeting discussion
b) Update on succession planning
26
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item V (ACTION): Finance Committee report - Leroy Wade, Treasurer
Action Item: ☒ Yes ☐ No
a) Third-quarter FY 2021 Finance Report
The finance report will be provided under separate cover.
b) Investment of Reserves
Update provided by Colorado Financial Management (Charles Schwab)
c) (ACTION) Approval of the NC-SARA Budget for FY 2022-23
The proposed FY 2022 budget will be provided under separate cover.
27
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item VI (ACTION): Federal Higher Education Landscape Impact on
NC-SARA – Catherine Guttman-McCabe
Action Item: ☐ Yes ☒ No
28
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item VII: Update on 21st Century Distance Education Guidelines – Sally
Johnstone and Barbara Brittingham
Action Item: ☐ Yes ☒ No
29
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item VIII: Branch Campus Working Group – Belle Wheelan and
Susan Heegaard
Action Item: ☐ Yes ☒ No
30
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Agenda Item IX (ACTION): Modifications to the SARA Policy Manual
Action Item: ☒ Yes ☐ No
Policy Change Modifications
a) Approve Section 3.2(a)(8) change to extend provisional status period under certain
circumstances.
b) Approve Section 3.2(e) change to extend provisional status specific to change of
ownership, for ongoing investigation, or for an extension of an accreditation
probationary period.
c) Approve 3.2(g)(2) policy language to align with changes in Section 3.2(e).
d) Approve removal of Section 8.3 to combine with Section 8.2 to ensure all policy
modifications are treated the same.
Policy Clarification Modifications
e) Approve Section 2.2(b) change to update the appeals language to reflect the
implementation of the policy by the passed deadline.
f) Approve Section 2.5(c) change to update the language to related to the federal
financial responsibility composite score (FRCS) pertaining to institutions and parent
companies.
g) Approve Section 2.5(d) change to update the appeals language to reflect the current
implementation of the policy.
h) Approve Section 2.6(c) change to update the appeals language to reflect the current
implementation of the policy.
i) Approve Section 3.8(c) policy language to align with the now implemented appeals
process.
j) Approve 5.10(b) policy change to remove the word “academic.”
k) Approve 6.2 policy change to remove screen shots associated with the process of
submitting institutional enrollment data.
Policy Change Modification- 21st Century Guidelines and C-RAC Guidelines
l) Approve 4.7 incorporation and transition to use of the 21st Century Distance
Education Guidelines to replace the retired 2011 C-RAC Interregional Guidelines for
the Evaluation of Distance Education (policy modification)
Proposed Modifications to the SARA Policy Manual
There are 12 proposed changes to the SARA Policy Manual. These are policy changes
recommended by the states, compacts, and NC-SARA staff as indicated below. There are five
31
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021(5) policy modifications and seven (7) policy clarifications.
Recommendation: Approve the proposed modifications.
Background. The SARA Policy Manual is issued periodically by NC-SARA; the current
version is Version 20.3, issued October 30, 2020, following the fall 2020 meeting. Successive versions
incorporate policy changes made by the NC-SARA Board and clarifications provided by the staff of NC-
SARA. The recommended modifications that follow, if approved, will result in a new Version 21.1
which will go into effect immediately following an affirmative board vote and will be released on the
NC-SARA web site within 30 days.
Policy Change Modifications
a) (ACTION) Approve Section 3.2(a)(8) change to extend provisional status period under certain
circumstances
Background: This change provides additional language to Section 3.2(a)(8) to ensure that a state has
the option to start a new provisional period for a change of ownership that will not count against the
provisional clock. This policy change will allow for a possible extension of provisional status in a
situation in which an institution is waiting to receive its new Federal Financial Responsible Composite
Score (FRCS). The additional time will not necessarily indicate greater risk of institutional closure and
in some cases the opposite is the case. This modification was proposed by MHEC and NC-SARA staff.
Alternatives Considered and Rationales
1) Do Nothing Scenario – Not Recommended
Leaving the policy unchanged puts students at risk of losing their programs in those
situations in which their institution has been on provisional status for financial issues and a
new owner takes over.
2) Attempt to revise all provisional status policy now to include additional
recommendations. - Not Recommended
NC-SARA staff received additional recommendations for policy revisions to include
more aspects of provisional status. These recommendations for this specific policy
revision as well as the others proposed at this board meeting that pertain to
provisional status were considered. After discussions with the four regional
compacts and several board members, it was determined that it is best to put
forward these policy proposals regarding provisional status at this time and review
additional possible revisions before another board meeting.
3) Revise policy to update given the date for state compliance has passed. – Recommended
Changing the policy to allow states more leeway in permitting a new provisional status period
32
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021for institutions under new ownership. The additional time may allow the institution to have its
new finances reviewed to obtain a new FRCS. As a result, the institution may remain in
business and its students continue their programs.
See red lined version of recommended modification below.
3.2 Provisional admission or renewal of an Institution
a. A state, at its discretion, may approve an institution applying for initial or renewal
participation in SARA to participate on Provisional Status in any of the following
circumstances:
1. The Institution is on provisional or probationary status or the equivalent with its
institutional Accrediting Agency;
2. The Institution is currently required by the U.S. Department of Education to post a
letter of credit or is under a cash management agreement with the U.S. Department of
Education (such institutions must still have a Federal Financial Responsibility
Composite Score of 1.0 or above);
3. The Institution has a Federal Financial Responsibility Composite Score between 1.0
and 1.5;
4. The Institution is the subject of a publicly announced investigation by a government
agency, and the investigation is related to the institution’s academic quality, financial
stability or student consumer protection;
5. The Institution is the subject of a current investigation by its Home State related to
the institution’s academic quality, financial stability or student consumer protection;
6. A third-party action such as a private lawsuit or news story does not by itself
establish a government investigation. If such a third-party event results in an
investigation by a government agency as set forth in subsections 3 and 4 above, these
subsections become applicable. Lawsuits by government entities are considered to
have resulted from a governmental investigation and can be the basis of a
determination of Provisional Status.
7. Lack of compliance with SARA policies related to data reporting.
8. The Institution has a change of ownership as determined by the Home State.
Additional changes of ownership of the same institution constitute a separate basis
for a state’s determination of provisional status. Each such determination begins a
new period of provisional status under Section 3.2(e).
9. The participating institution is in violation of, or noncompliance with SARA policies.
b) (ACTION) Approve Section 3.2(e) change to extend provisional status specific to change of
ownership, for ongoing investigation, or for an extension of an accreditation probationary period.
33
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021Background: This change provides additional language at 3.2(e) to ensure enough time when an
institution may need to extend provisional status due to financial calculations at the federal level or
for an investigation. This will allow for a possible extension of provisional status in a situation in
which an institution is waiting to receive its new Federal Financial Responsible Composite Score. The
additional time will not necessarily indicate greater risk of institutional closure and in some cases the
opposite is the case. The additional language will ensure continued provisional status during an
ongoing investigation or accreditor probationary status that has not been completed in two years.
This modification was proposed by MHEC and NC-SARA staff.
Alternatives Considered and Rationales
1) Do Nothing Scenario – Not Recommended
As indicated above in recommending the changes to section 3.2(a)(8), leaving the policy
unchanged puts students at risk of losing their programs in those situations in which their
institution has been on provisional status for financial issues, an investigation, or an extended
accreditor probationary period.
2) Revise policy to extend provisional status specific to change of ownership, for an
ongoing investigation or extended accreditor probationary period. – Recommended
Changing the policy allows states more leeway in permitting an extended provisional
status period for institutions undergoing a change of ownership, or under
investigation by another agency. The additional time may allow for the completion of
the investigation and determination of institution compliance with SARA policy.
See red lined version of recommended modification below.
Section 3.2(e). In no event shall such an extension of Provisional Status exceed one
additional year. An extension of Provisional Status shall not exceed one additional year
unless a change of ownership has occurred during the current period of provisional status
and additional time is needed to demonstrate compliance with federal requirements, or the
institution is on provisional or probationary status or the equivalent with its institutional
Accrediting Agency, or there is an ongoing investigation as described in Section 3.2(4) and
(5).
c) (ACTION) Approve 3.2(g)(2) policy language to align with changes in Section 3.2(e).
Background: This change clarifies policy language in Section 3.2(g)(2) to align with
recommended edits to Section 3.2(e). This modification was proposed by MHEC and NC-SARA
staff.
Alternatives Considered and Rationales
34
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 20211) Do Nothing Scenario – Not Recommended
Assuming Section 3.2(e) is revised as recommended, this section must also be revised to
align.
2) Revise policy to align with recommended revision to Section 3.2(g)(2) – Recommended
This is an additional policy section that would require revision to permit extensions
of provisional status under specific circumstances.
See red lined version of recommended modification below.
Section 3.2(g): If an Institution on SARA Provisional Status is found by its home state to not meet the
requirements of SARA, the home state shall disallow any further enrollments under SARA, shall notify
its Regional Compact and NC-SARA, and:
1. Remove the institution from SARA participation, or
2. Allow the institution a period of time not to exceed 12 months in which to come into
compliance with SARA policies under state supervision. Only one such time period is allowed
in any three-year period, unless the extension is due to an ongoing investigation or as a result
of a change of ownership during the current period of provisional status and additional time is
needed to demonstrate compliance with federal requirements.
d) (ACTION) Approve removal of Section 8.3 to combine with Section 8.2 to ensure all policy
modifications are treated the same.
Background: This change removes section 8.3 to combine with 8.2 to remove distinctions
between types of policy changes. The subjectivity associated with the previous distinctions
made between types of changes has proved problematic. Without this difference, all
modifications are treated the same. This modification was proposed by NC-SARA staff with
input from regional compact staff, SARA State Portal Entity staff and other stakeholders. A
section describing process, which is not usually included in policy, was recommended by
WICHE to remain.
Alternatives Considered and Rationales
1) Do Nothing Scenario – Not Recommended
Not changing this policy section will continue to describe distinctions in policy
types that are no longer made.
2) Revise policy to align with recommended revision to Section 3.2(e). – Recommended
This change will remove differences in types of policy modifications such that all are
considered with openness and transparency.
35
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021See red lined version of recommended modification below.
8.2 Minor Modifications
a. Process: Questions, comments, or suggested modifications to SARA policies, from
institutions and other key stakeholders, may be brought to the attention of:
• SARA State Portal Entity (SPEs) portal entity directors in SARA member
states;
• SARA directors in the Regional compacts;
• Regional SARA regional steering committees; or
• The President or staff of the National Council for State Authorization
Reciprocity Agreements (NC-SARA).
Persons making such requests should provide a rationale supporting their request. Such
request will normally be considered at the state level first, followed by consideration by the
relevant SARA regional steering committee. If any such request gains the approval of the
regional compact’s SARA steering committee, the President at earliest opportunity shall
share place that request on the agenda of the NC-SARA Executive Committee of the Board for
its consideration, or if necessary, make other arrangement for Board consideration.
Such communications shall be dealt with in as expedient a manner as possible, while
ensuring broad consultation and consistency across the SARA community. Unresolved
questions, concerns, or comments shall involve further consultation among SARA State Poral
Entity (SPEs) portal entity directors, regional compacts and NC-SARA staff. The NC-SARA
President and NC-SARA staff shall work with regional directors compacts to develop and/or
propose responses. As appropriate, that process may include consultation with the SARA
regional steering committees in the regional compacts and with the NC-SARA Board. The
President of NC-SARA is responsible for ensuring that responses are developed.
In responding to and ultimately acting on such requests, NC-SARA staff and the regional
compacts shall evaluate proposed changes in light of SARA’s fundamental reliance on
interstate reciprocity and trust, and on the fundamental purposes of SARA, which are to
support high quality distance education, resolve problems encountered by students, and
simplify and support the interstate offering of distance education using a model under which
an institution’s home state is primarily responsible for what the institution offers under the
aegis of SARA.
Other guiding principles for the review, clarification and modification of SARA policies include:
• Broad consultation with stakeholders;
• Maintaining consistency in policy and procedures;
• Transparency and openness; and
• Responsiveness to stakeholders and emerging policy issues.
36
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021b. Minor Modifications: The President may approve and promulgate clarifications and minor
modifications that do not substantively change SARA Policies, after concluding the
consultative process described above.
8.3 Significant modifications
Ultimately, it is the responsibility of the President and CEO of NC-SARA to ensure broad
consultation among the Regional Compacts, NC-SARA, and the SARA community at large in
developing responses to requests for significant modifications to the SARA Policy Manual.
Requests for significant changes should be addressed to the President and CEO of
NC-SARA, who will work with the Regional Compacts, their SARA steering committees, the
NC-SARA executive committee, and the NC-SARA Board to ensure consideration and
resolution. Persons making such requests should provide a rationale supporting their
request. Such requests will normally be considered at the state level first, followed by
consideration by the relevant SARA regional steering committee. If any such request gains
the approval of a regional compact’s SARA steering committee, the President at earliest
opportunity shall place that request on the agenda of the NC-SARA Board for its
consideration, or, if necessary, make other arrangements for Board consideration.
In responding to and ultimately acting on such requests, regional and national SARA staff and
oversight committees shall evaluate proposed changes in light of SARA’s fundamental
reliance on interstate reciprocity and trust, and on the fundamental purposes of SARA, which
are to support high quality Distance Education, resolve problems encountered by students,
and simplify and support the interstate offering of Distance Education using a model under
which an Institution’s Home State is primarily responsible for what the Institution offers
under the aegis of SARA.
Other guiding principles for the review, clarification and modification of SARA policies include:
• Broad consultation with key stakeholders;
• Maintaining consistency in policy and procedures;
• Transparency and openness; and
• Responsiveness to stakeholders and emerging policy issues.
37
National Council for State Authorization Reciprocity Agreements (NC-SARA)
NC-SARA Board Meeting | Virtual | May 4-5, 2021You can also read
