SARA (State Authorization Reciprocity Agreements) Process for Resolving Complaints and Conflicts

Contact: Teaching and Learning Technologies
Updated: 1/24

NC-SARA sealProcess for resolving complaints and conflicts
William Jewell provides students with Information to help them make informed decisions about their education. The William Jewell Student Consumer Information can be found here. Information on the process for reporting and resolving complaints through the College using the General Grievance Policy may be found here. You may also find a copy of SARA’s Complaint Resolution Policies and Procedures below. SARA’s policies only apply to students from outside of the State of Missouri participating in online classes through William Jewell College. Complaints that have been exhausted through William Jewell’s general grievance process should be sent to Joshua Fischer, Joshua.Fischer@dhewd.mo.gov, (573) 522-1377 at the Department of Higher Education and Workforce Development.

Missouri Department of Higher Education Policy
The Coordinating Board of Higher Education has published a policy on complaint resolution which may be accessed here.

Out-of-State Students Taking Courses Under the State Authorization Reciprocity Agreements
The following policies appear in Version 22.1 of the State Authorization Reciprocity Agreements Manual, published June 27, 2022. These are the policies with which William Jewell College must comply as part of its membership in SARA.

Section 4. Consumer Protection
4.1 Applicability
Provisions of the SARA Policy Manual, including those for consumer protection and the resolution of Complaints, apply to interstate Distance Education offered by participating SARA Institutions to students in other SARA States. Only those Complaints resulting from Distance Education courses, activities and operations provided by SARA-participating Institutions to students in other SARA States come under the coverage of SARA. Complaints about a SARA Institution’s in-state operations are to be resolved under the State’s normal provisions, not those of SARA. EXPLANATORY NOTES: SARA Member States continue to have authority to enforce all their general-purpose laws against Non-domestic out-of-state Institutions (including SARA-participating Institutions) providing Distance Education in the State, including, but not limited to, those laws related to consumer protection and fraudulent activities.

4.2 Role of Home State
SARA consumer protection provisions require the Home State, through its SARA State Portal Entity, to investigate and resolve allegations of dishonest or fraudulent activity by the state’s SARA-participating institutions, including the provision of false or misleading information.

4.3 Examples of Consumer Protection Issues
Examples of issues that may arise in regard to alleged fraudulent activity, violations of SARA policies or more general Complaints about improper activities include, but are not limited to:

a. Veracity of recruitment and marketing materials;

b. Accuracy of job placement data;

c. Accuracy of information about tuition, fees and financial aid;

d. Complete and accurate admission requirements for courses and programs;

e. Accuracy of information about the Institution’s accreditation and/or any programmatic/specialized accreditation held by the institution’s programs;

f.  Accuracy of information about whether course work meets any relevant Professional Licensing requirements or the requirements of specialized Accrediting Agencies;

g. Accuracy of information about whether the Institution’s course work will transfer to other Institutions; and

h. Operation of Distance Education programs consistent with practices expected by institutional accreditors (and, if applicable, programmatic/specialized accreditors) and/or the C-RAC Guidelines for Distance Education.

4.4 Responsibilities for Resolving Complaints

a. Institutions operating under SARA policies shall provide their and SARA’s Complaint resolution policies and procedures to all students taking courses under SARA policies.

b. Initial responsibility for the investigation and resolution of Complaints resides with the Institution against which the Complaint is made. Further consideration and resolution, if necessary, is the responsibility of the SARA State Portal Entity and other responsible agencies of the Institution’s Home State (see the following sections: Complaint Resolution Processes and Section 2.5 herein).

c. The State Portal Entity is responsible for conducting the investigation and resolution of Complaints that are not resolved at the institutional level. The SARA State Portal Entity may enlist the assistance of other responsible entities in the State in carrying out the work of Complaint resolution. EXPLANATORY NOTES: If a Home State does not currently handle investigations and consumer protection for all of its Distance Education providers, will the Home State need to start doing that? Yes. SARA centralizes primary responsibility for problem-solving in the Home State, therefore the Home State needs to be prepared to handle a larger volume of communication and issues for its domiciled, SARA-participating providers, even as its work with providers based in other States decreases. See federal rules for possible additional requirements.

d. The State Portal Entity is ultimately responsible for ensuring that a valid complaint results in proper redress. The State Portal Entity may delegate responsibility to investigate and resolve such Complaints to another government agency (e.g., a Board of Regents) or to a special body created to handle SARA Complaints for a group of Institutions, but must have and retain the function of hearing any appeals from decisions made by other agencies. The SARA State Portal Entity cannot merely have advisory powers; it must have the formal authority to provide final resolution of SARA-related Complaints and ultimately to remove any Institution, public or private, from the state’s list of SARA-eligible providers if that Institution fails to abide by SARA policies.

e. No SARA Member State, gives up its ability to investigate misrepresentation, fraud or other illegal activity by Institutions based in other states, including SARA-participating Institutions.

f. SARA Member States retain the ability to use any of their general-purpose criminal or consumer protection laws against an Institution that violates those laws. State oversight of distance education delivered by a SARA-participating Institution to students in any SARA Member State is centralized by SARA policy in the college’s Home State.

g. Mandatory arbitration agreements do not pertain to SARA policy, and, as such, SARA participating institutions are not permitted to enforce these on students enrolled under SARA provisions. Disputes between students and institutions on SARA-related matters are to be resolved by the institution’s SARA State Portal Entity following the SARA complaint process outlined in Section 4.5 or through other means. Institutions that utilize mandatory arbitration agreements for the resolution of non-SARA complaints or disputes shall provide a disclosure that such agreements must not be applied towards a complaint or dispute that falls within the scope of the SARA Policy Manual. [Implementation date July 1, 2024]

4.5 Process for Resolving Complaints

a. Complaints against an Institution operating under SARA policies go first through the Institution’s own procedures for resolution of grievances. Allegations of criminal offenses or alleged violations of a State’s general-purpose laws may be made directly to the relevant State agencies.

b. Complaints regarding student grades or student conduct violations are governed entirely by institutional policy and the laws of the SARA Institution’s Home State.

c. If a person bringing a Complaint is not satisfied with the outcome of the institutional process for handling Complaints, the Complaint (except for Complaints about grades or student conduct violations) may be appealed, within two years of the incident about which the Complaint is made, to the SARA Portal Entity in the Home State of the Institution against which the Complaint has been lodged. That SARA State Portal Entity shall notify the SARA Portal Entity for the State in which the student is located of receipt of that appealed Complaint. The resolution of the Complaint by the Institution’s Home State SARA Portal Entity, through its SARA State complaint resolution process, will be final, except for Complaints that fall under the provision “g” below.

d. While the final resolution of the Complaint rests with the SARA Portal Entity in the Home State of the Institution against which the Complaint has been lodged, the SARA State Portal Entity in the complainant’s location State may assist as needed. The final disposition of a Complaint resolved by the Home State shall be communicated to the SARA State Portal Entity in the State where the student lived at the time of the incident leading to the Complaint, if known.

e. While final resolution of Complaints (for purposes of adjudication of the Complaint and enforcement of any resultant remedies or redress) resides in certain cases with institutions (Complaints about grades or student conduct violations), or more generally with the relevant Institution’s Home State SARA Portal Entity (all other Complaints), the Regional Compact(s) administering SARA may consider a disputed Complaint as a “case file” if concerns are raised against a SARA member State with regard to whether that State is abiding by SARA policies, as promulgated in the SARA Policy Manual. The Regional Compact may review such institutional concerns in determining whether a State under its SARA purview is abiding by SARA policies. Similarly, a Complaint “case file” may also be reviewed by NC-SARA in considering whether a Regional Compact is ensuring that its SARA member States are abiding by the SARA policies required for their membership in SARA.

f. SARA State Portal Entities shall report quarterly to NC-SARA the number and disposition of appealed Complaints that are not resolved at the institutional level. NC-SARA shall make that information publicly available on its website. Such data will create transparency and can be used in determining whether a Regional Compact is ensuring that its SARA member States and those States’ Institutions are abiding by the policies required for State membership and institutional participation in SARA.

g. Nothing in the SARA Policy Manual precludes a State from using its laws of general application to pursue action against an Institution that violates those laws.

4.6 Oversight of Complaint investigation

Investigation of a SARA-related Complaint against an Institution requires that a State board, agency or entity outside the institution’s immediate management be available to handle Complaints that are not resolved within the Institution. A system board responsible for more than one separately Accredited institution may serve this role under SARA provisions. A board responsible for only one Accredited institution, or which lacks enforcement authority over an Institution, cannot serve as the SARA external oversight agency for such an Institution. In such circumstances, the Institution’s home-state SARA State Portal Entity may serve that function. EXPLANATORY NOTES: Is the requirement under SARA that a State have a Complaint process for all of its Institutions something that SARA invented? No. The requirement that States have such a complaint process is found in federal rules (Code of Federal Regulations) 34 CFR 600.9(a)(1). Complaints handled under SARA must comply with procedures established in federal rules.

4.7 Incorporation and use of C-RAC Guidelines
Consumer protection within SARA, in addition to dealing with alleged fraudulent activity, also provides for the investigation and resolution of Complaints that an Institution is operating a course or program contrary to practices set forth in the C-RAC Guidelines in such a way that a student is harmed. (The Interregional Guidelines for the Evaluation of Distance Education [Online Learning] are referred to as “C-RAC Guidelines” in this document). C-RAC Guidelines adopted by the Council of Regional Accrediting Commissions are incorporated in the requirements of SARA as policies. States that join SARA need to base their oversight of SARA activity and their investigative actions on the following expectations. The president or chief academic officer of each Institution participating in SARA (whether Accredited by a “regional” or other recognized accreditor) shall attest that their Institution meets and agrees to comply with the following C-RAC provisions.

  • Online learning is appropriate to the Institution’s mission and purposes.
  • The Institution’s plans for developing, sustaining, and, if appropriate, expanding online learning offerings are integrated into its regular planning and evaluation processes.
  • Online learning is incorporated into the institution’s systems of governance and academic oversight.
  • Curricula for the Institution’s online learning offerings are coherent, cohesive, and comparable in academic rigor to programs offered in traditional instructional formats.
  • The Institution evaluates the effectiveness of its online learning offerings, including the extent to which the online learning goals are achieved, and uses the results of its evaluations to enhance the attainment of the goals.
  • Faculty responsible for delivering the online learning curricula and evaluating the students’ success in achieving the online learning goals are appropriately qualified and effectively supported.
  • The Institution provides effective student and academic services to support students enrolled in online learning offerings.
  • The Institution provides sufficient resources to support and, if appropriate, expand its online learning offerings.
  • The Institution assures the integrity of its online offerings.

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