State Authorization

Due to federal and state regulations, all universities offering online courses, online degrees, and face-to-face activities such as internships in states other than their own must meet the unique state authorization requirement and regulations of those states. Commonwealth University participates in the National Council for State Authorization Reciprocity Agreements (NC-SARA) via the Pennsylvania Department of Education. As a participant of NC-SARA, Commonwealth University shares distance learning reciprocity with 49 states, the District of Columbia, Puerto Rico, and the US Virgin Islands. Commonwealth University is also able to offer many programs in California. SARA has no effect on state professional licensing requirements. Please click the Professional Licensure and Certification Public Disclosures link below for more information.

State Authorization Reciprocity Agreements (SARA)

State Authorization Reciprocity Agreements (SARA) are agreements among member states, districts, and territories that establish comparable national standards for interstate offering of postsecondary distance education. Member states recognize participating institutions that are authorized in other member states. The intention is to make it easier for students to take online courses offered by postsecondary institutions based in another state. SARA-participation also allows students to have non-licensure program field experiences in other SARA-member states. Visit for more information.

It is highly recommended that international students considering an online or on-campus academic program leading to professional licensure or certification first confirm with the applicable professional licensing entity in their country of residence and/or country in which they intend to work as to whether the CU program/degree is formally recognized. This includes, but is not limited to, when seeking licensure, certification, certain types of employment, and/or when enrolling in subsequent educational programs.

An institution must make a determination, in accordance with the institution’s policies or procedures, regarding the state in which a student is located, which must be applied consistently to all students. (34 CFR § 600.9(c)(2)) The difference between “location” and “residence” plays an important role in Commonwealth University maintaining compliance with a number of regulations. “Location” is where a student is physically situated while participating in a University course of study. “Residence” applies to the state where a student votes and/or holds a driver’s license. Commonwealth University student location is initially determined by the information provided by the student at the time of enrollment. Student location is updated upon formal receipt of information from the student by the University that the student’s location has changed to another state. Student location may be changed through these University processes:

  • A notice will go out to students at or near the start of each semester to ask them to indicate their physical locations for the semester they are currently enrolled in.
  • Make subsequent updates throughout a semester by contacting the Director of Survey Research and Compliance, John Cosgrove, Ph.D.

Please Note: For SARA and SARA-related purposes, new student initial enrollment at Commonwealth University occurs at the start of each semester and not upon registering for classes or working out financial aid packages.

Commonwealth University strives to provide the highest quality educational programs available but recognizes the importance of providing an opportunity for students to make an appeal if a conflict does arise. As a SARA participating institution, CU has agreed to abide by the SARA student complaint process for distance education student complaints not related to grades or conduct. (Student complaints regarding grades or student conduct violations are governed entirely by institutional policy and Pennsylvania laws, not through the state portal agency.)

Distance education students residing outside of Pennsylvania who have a grievance, complaint, or concern should attempt to resolve the issue internally in accordance with PRP 3592. Students who are unable to resolve the issue through the faculty member, department chair, and/or the dean may submit a complaint in writing via email to Dr. Gretchen, Interim Vice Provost and Dean of Undergraduate Education, at Please note that grievances, complaints, or concerns submitted via this process with regard to a particular course, program, or department may be forwarded and discussed with the faculty member, department, or academic dean for resolution.

Distance education students who are unable to resolve the issue internally may contact the SARA portal agency of Pennsylvania within two years of the incident regarding the complaint. The PA portal agency will collaborate with the SARA portal agency of the state where the student is located to resolve the issue. California is not a SARA-member state at this time. A student participating in distance education while located in California should appeal to the appropriate agency specified in the "Student Complaint Information by State and Agency" document.

All other current, former, or prospective students who feel that their grievances, complaints, or concerns cannot be resolved by the University in accordance with PRP 3592 and the resources provided by the Dean of Students may file a complaint with the Pennsylvania State System of Higher Education (State System) by completing in its entirety the Student Complaint Form. Information regarding the PASSHE Student Complaint Process may be found at:

Complaints not resolved at the State System level may be appealed to the University’s accreditor, Middle States Commission on Higher Education (MSCHE) according to the MSCHE complaint process.

Please visit the complaints and concerns page for additional student complaint information.

Frequently Asked Questions

What is State Authorization?
State Authorization is a legal term that applies to a university’s compliance with the rules and regulations of each state in which it serves students. Each institution of higher education is individually required to seek authorization to provide online education to students who reside in states other than its home state as well as to allow its students to participate in out-of-state field experiences, such as internships and clinicals. Important Note: Programs that typically lead to licensure to practice in the field, such as nursing and education, may require additional approval from another state’s licensing entity before being permitted to provide online learning to that state’s residents or to send CU students to that state for field experiences.

Professional Licensure/Certification: If I am a CU student or prospective student who would like to participate from or in a state other than PA, either in an online course or a field placement in a program leading to a license/certification (Education, Nursing, AuD, Social Work, MAcc, and others), what should I do?
Before starting such a program, we encourage you to: 1. Review the Professional Licensure and Certification Public Disclosures on Commonwealth University’s State Authorization webpage. 2. If you are unsure if your program requires special authorization, contact the Director of Survey Research and Compliance, John Cosgrove, Ph.D., to ensure the approval of the program in the state where you will be physically located at the time of instruction or field experience. 2. Contact the appropriate licensing board of the state where you will be physically located to confirm licensing laws and requirements in that state. 3. Contact the director of the CU program to review that state’s licensing requirements.

Does SARA mean that Commonwealth University doesn’t have to worry about State Authorization anymore?
SARA streamlines the authorization process, but it doesn’t cover all activities outside of Pennsylvania. CU is still required to comply with each state’s professional licensing board requirements. The National Council of SARA (NC-SARA) has its own policies that CU agreed to follow, such as the “rule of 10”, which refers to a limit on the number of students placed in out-of-state field experiences (up to 10 students per site per program at one time). CU’s Director of Survey Research and Compliance is charged with maintaining SARA renewal annually, as well as submitting annual data reports on student out-of-state physical locations for both distance education and field experiences. (Student ID is protected in accordance with FERPA.) To learn more about SARA and to view the SARA manual, visit

What if I am a CU student in a field experience or an online program leading to licensure and I’m planning on moving to another state?
State Authorization for SARA purposes refers to where you are physically located during your instruction or field experience, which may or may not be the location (US state or territory) of your legal residence. Relocation may impact your plan of study, progression in the program, and the ability to secure appropriate clinical placements, internships, or other types of field experiences. If you relocate to a state or country where CU is not permitted to offer your program, we cannot guarantee your ability to continue in the program. You are encouraged to contact CU’s Director of Survey Research and Compliance at least one term (15 weeks) in advance of your intended move to enable collaboration with your program director and academic advisor so that every effort can be made to accommodate your relocation.

Need answers to other State Authorization questions?
Contact Director of Survey Research and Compliance, John Cosgrove, Ph.D.

Colorado Workers' Compensation Statute Pertaining to Student Field Experiences

Due to Colorado regulations regarding workers’ compensation, only paid field experiences are permitted. Statutory Citation and Language of the Colorado Revised Statute 8-40-302 (7)


(a) Any employer, as defined in section 8-40-203, who enters into a bona fide cooperative education or student internship program sponsored by an educational institution for the purpose of providing on-the-job training for students shall be deemed an employer of such students for the purposes of workers' compensation and liability insurance pursuant to articles 40 to 47 of this title.

(b) If the student placed in an on-the-job training program does not receive any pay or remuneration from the employer, the educational institution sponsoring the student in the cooperative education or student internship program shall insure the student through the institution's workers' compensation and liability insurance or enter into negotiations with the employer for the purpose of arriving at a reasonable level of compensation to the employer for the employer's expense of providing workers' compensation and liability insurance while such student is participating in on-the-job training with said employer. This paragraph (b) shall not apply to a student teacher participating in a program authorized pursuant to article 62 of title 22, C.R.S.

(c) As used in this subsection (7), "cooperative education or student internship program" means a program sponsored by an educational institution in which a student is taught through a coordinated combination of specialized in-the-school instruction provided through an educational institution by qualified teachers and on-the-job training provided through a local business, agency, or organization or any governmental agency in cooperation with the educational institution.

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