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The Role of "Location" in State Authorization

“Location” refers to the physical location of a student, a faculty member, an educational activity, and/or an administrative activity. Certain conditions around the location of people or activities will trigger “physical presence,” which means that the institution must take extra steps to ensure that JMU is within the law regarding interstate delivery of education ("interstate" includes the 50 U.S. states, all U.S. territories, and the District of Columbia). 

Fortunately, JMU's participation in the State Authorization Reciprocity Agreement (SARA) allows its students and faculty to engage in many educational activities outside of Virginia without JMU needing to seek additional permission. Situations in which JMU does and does not need to seek permission are described below.

Location of the Student

In the context of state authorization, a student’s “location” is the state or territory where the student is located at various times during their academic career; this is not necessarily the student’s official state of residence. For example, a student's residence could be Virginia, but if they are engaged in a field experience in Nevada, their location is Nevada. Therefore, JMU must ensure that it has permission to place the student in that field experience in Nevada.

Fortunately, JMU's participation in the State Authorization Reciprocity Agreement (SARA) allows its students to participate in many educational activities outside of Virginia without needing to seek additional permission:

  • Fully online education (see Fully Distant Students)
  • Limited supervised field experiences (certain restrictions apply -- see Field Experience)
  • Independent off-campus study, e.g. independent field work for a thesis or dissertation, by individual students not engaged in a supervised field experience or in direct contact with the student’s institutiong  

However, the SARA agreement does not relieve an institution from needing to notify a student or prospective student of a licensure program (i.e., a program designed to lead to licensure) if that program does not meet or JMU has not yet determined if it meets the educational requirements for licensure in the student's or prospective student's location (i.e., the state or territory in which the individual is located at certain times). The student's or prospective student's location must be considered prior to enrollment in a licensure program, prior to placement in an out-of-state learning placement, and if and when a student relocates while enrolled in the program.

Location of teaching faculty

An institution may employ faculty who live outside its home state, including faculty who live outside the United States, to teach in programs offered under the jurisdiction of the home state. However, if the faculty member instructs a “short course” that requires more than 20 contact hours in one six-month period in another state or territory, or works from an institution-provided office space, physical presence is triggered and the institution must take additional steps to be in compliance. Contact JMU's State Authorization Compliance Officer for assistance and information.

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