Announcing new legal services from Hogan Lovells related to state authorization requirements

Much has changed in the area of state regulation of higher education since the U.S. Department of Education (ED) first proposed changes to federal student financial aid state authorization rules in 2010. Although ED is expected to propose further changes to those rules in 2018, our clients’ needs in this area have fundamentally changed with the nearly complete implementation of the State Authorization Reciprocity Agreement (SARA). For example, while 50-state surveys of physical presence requirements for purposes of distance education programs are no longer as critical or as relevant as they once were for most institutions, other important needs have emerged, such as how to navigate the requirements of SARA, how to address state professional licensure requirements, and how to maintain compliance internationally.

In view of these trends, and after consultation with clients, we are pleased to offer two distinct alternative fee packages for your consideration. In addition, a separate service will be offered as to international compliance for online programs, which will leverage our extensive global resources. The two domestic services are as follows:

1. Service for SARA institutions (fixed-fee)

Low-cost, quarterly fixed-fee service includes:  

  • advice with respect to SARA policies and procedures;
  • advice with respect to SARA applications and renewals;
  • advice with respect to compliance with ED rules related to distance education;
  • advice as to maintaining compliance with SARA requirements (e.g. clinical programs, composite scores, etc.); and
  • optional tracking and advice regarding online, graduate-level nursing and teaching programs for an additional fee.

This service is advisory in nature and does not include engagements that go beyond advising on the above matters, such as work on applications or representation in the context of disputes with state agencies.

2. Service for non-SARA institutions (special blended rate)

Special blended rate covers:  

  • advice on state authorization for California and other non-SARA institutions;
  • advice to non-degree institutions and ed-tech companies, no matter where they are located (e.g. boot camps, MOOCs, unaccredited alternative providers, etc.);
  • assistance with state applications, including for new, on-ground campuses; and
  • additional resource materials available on HL Engage website.

The special blended rate does not apply to controversies and disputes or accreditation matters.

We look forward to discussing these options with you further. In the meantime, if you have any questions, please feel free to contact Greg Ferenbach, Stephanie Gold, or Jeannie Yockey-Fine.


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