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Non-NY State Authorization and Distance Education

State Authorization refers to the regulation of both (1) distance education courses and programs offered to residents of a particular state by an institution based in another state, and (2) various non-distance activities within a particular state by institutions outside of that state.

For approval of distance education programs in New York State, click here.

Distance education is defined as a system and a process that connects learners with providers via distributed learning resources. While distance learning takes a wide variety of forms, all distance learning is characterized by: a separation of place and/or time between instructor and learner, among learners, and/or between learners and learning resources. If your school offers courses or programs in the form of distance education to students who do not reside within New York State while completing their studies, the information that follows will apply to you.

In addition, if your school or program has activity in the following catagories: non-classroom experiences, marketing and/or advertising, or proctoring, State Authorization may also apply to you. 

Each of the categories below, depending on the nature or level of activity, constitute what a state might consider a physical presence within its borders by an out-of-state institution, whether or not related to a  distance education program, and thus will necessitate state authorization.

Each individual state has created its own set of standards and guidelines with respect to educational activities within its borders by out-of-state institutions.

If your school or program meets or plans activities with respect to distance education courses or programs or non-distance program offerings which will meet any of the following catagories as defined below, please contact Brianna Bates, Assistant Director in the Office of Academic Program Review at or (212) 998-2388. 

The following categories highlight when State Authorization is required:

Non-Classroom Experience: Internships, externships, field experience, clinicals, practicums, student teaching and medical clerkships

Specific states have classified "on the ground" educational activities, even when part of a distance education course or program, as constituting a physical presence and need for authorization within their state. If a student is completing any non-classroom credit bearing component or general requirement for any program outside of New York State, authorization within the specific state may be required prior to completion of the educational activity. This includes: internships, externships, clinicals, practicums, student teaching and medical clerkships.

Please click here to access a current chart summary of the non-classroom experience restrictions for NYU.


Distance Education

For NYU programs that are 100% distance education, student enrollments are restricted in the following states:

  1. Alabama
  2. Alaska
  3. Arkansas
  4. Oregon
  5. Utah
  6. Wisconsin
  7. Minnesota  

Please include a disclaimer on your website that conveys this information. A sample statement could be "students from x, y and z states are restricted from enrollment at this time."

Continuing Education Credits (CEU)

Currently, 13 states have regulations that require educational institutions to secure state authorization prior to offering Continuing Education Credits (CEU) via distance education to residents of their state. NYU has already secured approval in five of these states. Eight remain, from which enrollments should be restricted until further notice:

  1. Alabama
  2. Alaska 
  3. New Hampshire 
  4. Oklahoma
  5. Oregon
  6. Texas*
  7. Utah 
  8. Wisconsin

A common question is whether or not a program can offer a student access to the CEU, but not grant credits to them if they are from a restricted state and still remain in compliance. Unfortunately, even without offering CEU's, individuals in the restricted states won't be able to access the materials. The State Authorization issue has grown out of a consumer protection focus. Even without CEU's being granted, just delivering distance education to students in the respective states in exchange for payment could trigger a state to notify the University of non-compliant activity. Restricting enrollments is best practice to protect the University from liabilities and potential fines for non-compliance. It is essential that (for now) individuals residing in these states simply be restricted from enrolling.

*Distance learning students from Texas may enroll if schools post a conspicuous notice on the home page of their websites with the following information:

  1. disclosure that the career school or college is not regulated in Texas under Chapter 132 of the Texas Education Code;
  2. the name of any regulatory agencies that approve and regulate the school's programs in the state where the school is physically located and in which it has legal authorization to operate; and
  3. how to file complaints or make other contact with applicable regulatory agencies.


States have defined marketing and/or advertising within their borders as constituting a physical presence and need for authorization prior to an out-of-state institution being allowed to advertise by local and/or national means. This includes but is not limited to: having recruiting agents or sales representatives active within the state, print advertising, radio advertising, television advertising. Currently, NYU restricts marketing and/or advertising activity in the states listed below. 

Distance Education SpecificGeneral
Local                   National Local                 National
                          Oklahoma Arkansas
  Massachusetts   Massachusetts
  New Mexico
  South Carolina
  West Virginia
Marketing/Advertising/Recruiting Restrictions


Specific states have deemed activity related to the proctoring of exams or assignments within their state to constitute a physical presence in that state. Currently, NYU restricts proctoring activity in the states listed below. 

Delaware (only restricted in classroom setting)
New Hampshire
Rhode Island
West Virginia
Proctoring Restrictions

Faculty State of Residence  

Specific states have seemed the hiring of their residents as faculty for distance education program offerings  by a non-local academic institution to constitute a physical presence in that state. Currently, NYU restricts faculty serving this purpose that reside in the states listed below.


Employing full-time and/or adjunct faculty in the state to provide instruction via distance education programs to students in the stateEmploying full-time and/or adjunct faculty in the state to provide instruction via distance education programs to students outside of the stateEmploying full-time and/or adjunct faculty in the state to provide instruction via distance education programs to students both inside and outside of the state
Georgia District of Columbia Alaska
  North Dakota Iowa
  Oklahoma Kansas
    Puerto Rico
    Rhode Island

Additional Triggers

In addition to the items listed above, the following are often defined by a state as constituting a physical presence within its borders and therefore requiring authorization. If a school or program has any of the following, please notify our office so that we can plan accordingly for compliance: 

  • Any computer servers located in a state other than New York
  • A phone number generated from a state other than New York 
  • An IP (internet provider) address generated from a state other than New York

Statement of Compliance Status

NYU has made/is making a good-faith effort and is complying with these regulations in the following ways:

  • NYU has contacted all state regulators to determine what requirements each state has for being authorized
  •  NYU is completing applications to be authorized when necessary
  • NYU has procedures for tracking the changing requirements in states


College of Arts and Science
Tristan Kirvin
Assistant Director, Academic Programs

College of Dentistry
Andrew Spielman
Associate Dean

College of Nursing
Barbara Krainovich-Miller
Associate Dean

Gallatin School of Individualized Study
Celeste Orangers
Assistant Dean

Global Institute of Public Health
Martina Lynch
Director of Planning and Assessment

Graduate School of Arts and Science
Allan Corns
Associate Director, Academic Affairs

Leonard N. Stern School of Business
Roy Lee
Assistant Dean of Global Programs

Thomas Pugel
Vice Dean for MBA Programs

Office of General Counsel
Tom Kozak
Associate General Counsel

Office of Global Programs
Janet Alperstein
Senior Director, Academic Support

Office of Government Relations
Steve Heuer
Director, Government Relations

Office of Undergraduate Admissions
Shawn Abbott
Assistant Vice President for Undergraduate Admissions

Polytechnic School of Engineering
Marlene Leekang
Director of Admissions and Enrollments

Robert F. Wagner Graduate School of Public Service
Katty Jones
Director of Program Services

School of Law
John Stephens
Director, Graduate Tax Program

School of Medicine
Mel Rosenfeld
Associate Dean for Medical Education

School of Professional Studies
Jessica Martin
Associate Director, Academic and Faculty Affairs

Silver School of Social Work
Tazuko Shibusawa
Associate Professor of Social Work; Associate Dean, Professional Programs; Director, MSW Program

Steinhardt School of Culture, Education, and Human Development
Heather Herrera
Director, Academic Affairs

Tisch School of the Arts
Carrie Meconis
Assistant Director


NYU State Authorization Meeting, December 2014: Ms. Brianna L. Bates, Assistant Director & Russ Hamberger, Associate Provost

State Authorization: Steps to Success, WCET 2014 Annual Meeting, Ms. Brianna L. Bates & Diana L. Karafin, Ph.D.

NYU State Authorization Meeting, April 2013: Ms. Brianna L. Bates, Accreditation Coordinator

State Authorization, ADEIL Conference October 2013: Ms. Brianna L. Bates, Accreditation Coordinator

Activity Forms

April 2013:

Click here to access the requested information sheet that should be uploaded within the survey. Please complete and upload the additional information sheet if any of your school programs or courses have one or both of the following:

1. The ability to complete an entire program or course via distance education and/or;

2. Any non-classroom offering (internship, externship, clinical, practicum, student teaching, field work, clerkship, etc). 

Please click here to complete the survey

October 2013:

If you received the memo requesting participation, click here to access the required non-classroom experience survey. This data will be used for compliance in MD, NC and MA.

Note: these surverys are now password protected and should not be used by other institutions without the permission from NYU. Please contact our office for additional information if interested.

Resources and Additional Information

State Higher Education Executive Officers Association (SHEEO): Click here to be redirected to the SHEEO website 

National Council for State Authorization Recprocity Agreement (NC-SARA): Click here to be redirected to the NC-SARA website

WCET State Authorization Network (SAN): Click here to be redirected to the WCET SAN website




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