Purpose of Determining Location

Per Federal Department of Education Regulations Title IV 34 CFR §600.9(c)(1)(ii), §600.9(c)(1)(iii), §668.43(c); and the National Council for State Authorization Reciprocity Agreements (NC-SARA) Policy, JMU must determine and record the physical location of its students who are currently enrolled in JMU courses, and prospective students of licensure programs. The location is the U.S. state or territory in which the student is living at certain times in their academic career. Location data are used for required reporting and other compliance responsibilities.

The following information specifies procedures to be followed per Academic Affairs Policy #14 Determination of Student Location.

Procedures for Determining Location of Currently Enrolled Students

The Federal regulations require JMU to determine the location of currently enrolled students when participating in learning activities. Based on the data, JMU must determine if an individualized disclosure is necessary and if so, deliver the disclosure. JMU also uses location data in required annual reports to NC-SARA. The method of determining student location must apply to all students.

JMU determines student location via the existing Student Check-In process, made available by the Office of the Registrar. The purpose of the Check-In process is to collect various current information from students, including the student's expected location while participating in learning activities.

Specific Procedures: 

  1. The Office of the Registrar expects students to log into MyMadison and complete the Check-In process during the few weeks before and after the beginning of each semester.
  2. The data are stored in JMU's Student Administration (SA) system.
  3. The office of Information Technology ensures that a query is available to generate a report used each semester to determine student locations.
  4. The State Authorization and Compliance Officer, or other designee of the Associate Provost of Online Strategy, queries the SA data each semester to determine if any disclosures are warranted based on a student's reported location.
  5. The Office of Planning, Assessment and Institutional Research (PAIR) queries the SA data to determine the number of fully distance students disaggregated by location, and shares the data with the State Authorization Compliance Officer or other designee of the Associate Provost of Online Strategy.
  6. Per NC-SARA procedures, the State Authorization Compliance Officer or other designee of the Associate Provost of Online Strategy uses the disagregated fully distance student data to complete the Exclusively Distance Education Enrollments report and submits the report to NC-SARA.

Procedures for Determining Location of Prospective Students of Licensure Programs

The Federal requirements require that prior to a prospective student making a financial commitment to a licensure program (i.e., a program designed to lead to professional licensure or certification), JMU must determine the prospective student's location and based on that location determine whether a direct individualized disclosure must be delivered to the prospective student. A disclosure is required if the prospective student is located in a state or territory in which the licensure program does not meet the educational requirements for licensure in that state or territory or if JMU has not yet determined whether it does. 

For purposes of JMU's individualized disclosure process required by the Federal regulations, a prospective student of a licensure program is an individual who has been accepted into the program and has not yet made a financial commitment to the program

Specific Procedures:

  1. Any academic department that offers a licensure program ensures that the program application includes an item requiring the student to indicate their location at time of application. This is often the prospective student's local address.
  2. The academic department directly or indirectly makes each prospective student's local address and other required data available upon request to JMU's State Authorization Compliance Officer or other designee of the Associate Provost of Online Strategy prior to the student’s initial enrollment into the program, i.e., prior to the student making a financial commitment to the program.

    a. The location must be noted as either an abbreviation or full name of the state or territory.
    b. In addition to the student's location, the department must provide the following data:
    • First Name
    • Middle Name or Initial (if applicable)
    • Last Name
    • Undergraduate Institution (for Accounting M.S. program only)
    • Program Name
    • Indication of Acceptance into Program 

  3. The data must be provided in a spreadsheet/table format that is compatible with Microsoft Excel software.
  4. Data are made available through a JMU-supported information system or another method determined suitable by the State Authorization Compliance Officer or another designee of the Associate Provost of Online Strategy.


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