What is a Physical Presence Activity?

Whether you’re new to state authorization or could use a refresher, you may have heard that the State Authorization Reciprocity Agreement (SARA) doesn't cover all out-of-state activities, also called physical presence activities. 

What is a phyiscal presence activity (previously called a "trigger activity"), and why is it so important to share these 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.

Conducting certain educational activities in other states requires institutions to seek authorization. These educational activities are called physical presence activities.

Physical presence 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.

Out-of-state activities covered by SARA are:

• Online course offerings
  Offering courses to students via distance education using methods that do not require students to gather physically in groups is permitted.
• Advertising
  Ohio State may advertise to students through print, billboard, direct mail, internet, radio, television, and other mediums.
• University employees residing in a member state and working remotely
  Faculty, adjunct faculty, mentors, tutors, recruiters and other academic personnel may reside in a member state and work from home or another private, non-institutional site, provided that these employees are not engaged in activities that would otherwise constitute as physical presence as defined by SARA.
• Field trips
  Students may engage in field trips to visit existing sites or facilities for academic purposes not involving establishment of residential or instructional facilities.

What SARA Doesn’t Cover

Certain out-of-state activities not covered by SARA result in 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 activate 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 result in 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 result in 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 result in the need to seek authorization.
   

Why Physical Presence 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 physical presence 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 physical presence activities and share those activities with the state authorization team. The state authorization team will research state requirements to participate in the activity and work with the relevant regulatory board to seek and maintain Ohio State authorization.

Faculty and staff should also brush up on their state authorization knowledge by enrolling in the 30-minute State Authorization 101 BuckeyeLearn course that breaks down the basics of state authorization and why it’s so important.

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