When an activity happens in another US state or territory, it can “trigger” the need to request authorization from that state prior to conducting the activity. While some triggering scenarios and activities are obvious (i.e. online courses or non-classroom experiences), many are not. This page offers information about the various scenarios that will trigger the need for state authorization outside of New York State (NYS).
NYU is a State Authorization Reciprocity Agreement (SARA) participating member. This membership provides out-of-state coverage for certain regulated activities in SARA participating states. Not all activities outside of outside of NYS are covered, and therefore require additional authorization.
Which of My Activities Requires Authorization?
The following scenarios do not have full compliance coverage, and therefore require time to request state authorization. For more information about these requirements and how to move forward with any of them, please contact us.
Places Where We Don’t Have SARA Coverage
California, other US Commonwealths, and US Territories are not SARA members. Therefore, we do not have SARA coverage in these regions. NYU is able to enroll California students in online courses that NYU offers nationwide. Please review the list of participating SARA member states and territories.
If a state licensing board regulates your school’s activity in that state, then your school must request authorization for that activity. SARA does not supercede any state professional licensing board regulations. Additional professional licensure requirements also apply.
Activities Physically In Another State
The following are often defined by a state as constituting a physical presence within its borders, and therefore requires authorization. If a school or program has any of the following, please notify our office so that we can plan accordingly for compliance:
- Teaching face-to-face instruction
- Non-classroom experiences with more than 10 students per site per program in a SARA state or region
- Any physical location in which NYU has provided for faculty, students or staff
- A phone number or address generated from a state other than New York
Where Faculty Live
While NYU is able to hire out-of-state residents as faculty for distance education program offerings in SARA states, additional state laws may apply. Schools should contact their HR representative should they wish to employ faculty outside New York State to confirm that other state laws do not apply.
Which of My Activities Can Be Conducted in SARA Member Regions?
Distance Education & Continuing Education (CE)
Students may enroll in online courses, including those for continuing education (CE) in SARA states. Additional state licensing board regulations may apply and require approval prior to advertising and enrolling students.
Non-Classroom Experiences With No More Than 10 Students Per Site Per Program
Non-classroom experiences are field experiences, internships, externships, clinicals, practicums, student teaching, and medical clerkships. Schools may place students up to 10 students per site, per program in any SARA state, and must request approval if they wish to place more than 10. Schools report these experiences to OAPRA three times a year. Additional state licensing board regulations may still apply and require approval prior to the experience.
Marketing, Advertising & Recruiting
Any marketing, advertising, or other forms of recruiting happening within a given state constitutes having a physical presence in that state. NYU's SARA membership allows these activities in SARA states that require approval or exemptions. Misrepresentation regulations still apply.
Some states deem activity related to the proctoring of exams within their state to constitute a physical presence in that state. NYU's SARA membership allows these activities in SARA states that require approval or exemption.
Which of My Activities Requires OAPRA Consultation to Determine if Authorization May Be Required?
If your activity is not mentioned in the above categories, then it requires additional consultation with the OAPRA. Examples of activities that require consultation, because they vary school-to-school, are listed below:
- Field trips
- Research experiences
- Independent off-campus study
- Independent field work
- Any activity not listed on this website occurring outside of New York State