What is a Trigger Activity?

Whether you’re new to state authorization or could use a refresher, you may have heard the term “trigger activity” and wondered what it means. What is a trigger activity, and why is it so important to share trigger activities with the state authorization team?

What SARA Covers

Federal, state and professional licensing board regulations impact online and on-ground education offered across state lines. Compliance with these regulations means that an Ohio State degree will be recognized and that a student will be eligible to sit for licensure in other states.

When an institution participates in certain activities in other states, it triggers the need to seek authorization. For that reason, those activities are called trigger activities.

Trigger activities are different in every state, but the State Authorization Reciprocity Agreement (SARA) created one uniform standard that applies to all 49 SARA member states. Participation in SARA, which Ohio State joined in 2015, authorizes the university to offer many out-of-state activities, such as online courses and many field experiences. However, not all out-of-state activities are covered by SARA. Those activities still trigger the need to seek separate state authorization.

What SARA Doesn’t Cover

Certain out-of-state activities not covered by SARA trigger the need to seek authorization:

  • Field experiences in a licensed field
    Out-of-state clinicals or internships required for a licensure program, such as nursing or physical therapy, may trigger licensing board authorization requirements in the state. For example, a state licensing board might require program approval, faculty licensure in the state, or approval of a clinical placement.
  • Online licensure programs
    Online programs in a licensed field, such as teaching or social work, may need to be reviewed and approved by the state licensing board before enrolling students in the state.
  • Placements of more than 10 students
    Placing more than 10 students from a program at a placement site (such as a hospital) simultaneously in another state may trigger the need to seek authorization. This SARA policy ensures students completing traditional programs within the state have adequate access to placement opportunities.
  • Establishment of a physical location
    Owning or leasing space for classrooms, offices or student support services may trigger the need to seek authorization.
  • Face-to-face contact
    Requiring students to meet in person or offering a short course (more than 20 hours) may trigger the need to seek authorization.

Why Trigger Activities Matter

A state licensing board may not accept an Ohio State degree if the program was not authorized or approved – meaning a student may not be eligible for licensure. In addition, participating in trigger activities without authorization could lead to civil penalties, fines, lawsuits, and loss of institutional reputation.

How You Can Help

Ohio State faculty and staff should monitor current and proposed trigger activities and share those activities with the state authorization team.  The state authorization team will research state requirements to participate in the trigger activity and work with the relevant regulatory board to seek and maintain Ohio State authorization.

Please contact the state authorization team with any questions about trigger activities or authorization requirements.