[S-SARA] SARA and HCM2

Fri Nov 1 14:57:53 CDT 2019

Hi, everyone.  Just in case anyone was wondering, here is the letter we sent to the institution with approval from our legal counsel.  We are working on getting signatures for the paperwork for NC-SARA.  Have a great weekend!

Kyle

Dear Dr. [NAME]:

Re:      [INSTITUTION] SARA Participation

At their [DATE] meeting, the Oklahoma State Regents for Higher Education approved [INSTITUTION]'s request to renew participation in the State Authorization Reciprocity Agreement (SARA) for another year.  As you are aware, the National Council for State Authorization Reciprocity Agreements (NC-SARA) has established guidelines for institutions to be eligible for participation in SARA.  When applying for initial approval or renewal in SARA, institutions affirm their commitment to abide by these guidelines.  For non-public institutions, this includes maintaining a financial responsibility index score from the U.S. Department of Education (USDE) of 1.0-1.49 for provisional approval or at least 1.5 for full approval.  On August 14, 2019, USDE published updated financial responsibility index scores for non-public institutions.  [INSTITUTION]'s published score was 0.2, placing the institution below the range of eligibility to participate in SARA.  Therefore, [INSTITUTION]'s approval to participate in SARA is withdrawn effective immediately.  [INSTITUTION] may reapply for participation in SARA once it meets all requirements for participation.

If you have any questions, please contact me by email at kfoster at osrhe.edu<mailto:kfoster at osrhe.edu> or by telephone at (405) 225-9163.

Sincerely,

Kyle Foster
Assistant Vice Chancellor for Academic Affairs

Kyle Foster
Assistant Vice Chancellor for Academic Affairs
Oklahoma State Regents for Higher Education
655 Research Parkway, Suite 200 | Oklahoma City, OK 73104<https://goo.gl/maps/nMc3YG81uo72>
P: +1 405 225 9163 | F: +1 405 225 9300 | E: kfoster at osrhe.edu<mailto:kfoster at osrhe.edu>
[OK_RegentHighEdu_4c_horz]<http://okhighered.org/>

From: S-SARA [mailto:s-sara-bounces at lists.onenet.net] On Behalf Of Levy, Sarah (CPE)
Sent: Tuesday, October 29, 2019 10:51 AM
To: s-sara at lists.onenet.net
Subject: Re: [S-SARA] SARA and HCM2

Kyle,

Sharing with the group:

We have proposed amendment to our licensing regulation re: HCM to require institutions to notify us within 10 days of HCM placement and re: coverage for unearned tuition - you can see the full agenda item starts at page 41, and specifically the proposed language re: HCM is on page 58: http://cpe.ky.gov/aboutus/agendas/cpe_meetings/agenda-103119.pdf  .

*         To clarify, this proposed amended licensing regulation 13 KAR 1:020 is a different regulation from our SARA regulation 13 KAR 4:010.

*         The next step in the process regarding this proposed amended licensing regulation is that it is on the agenda for the LRC's Administrative Regulation Review Subcommittee meeting on November 12 https://apps.legislature.ky.gov/CommitteeDocuments/3/12152/Tentative%20ARRS%20November%20Agenda.pdf .

In addition, I have scheduled on my calendar to check the USDoE webpage re: HCM status as USDoE updates it quarterly, and that is also part my financial review that I do as part of our annual licensure renewal process.  https://studentaid.ed.gov/sa/about/data-center/school/hcm

*         FYI - Here are two articles that provide a bit of history regarding two KY institutions that were on HCM2 and closed, and the USDoE's decision to start posting HCM status on its webpage beginning in 2015:

o   https://www.insidehighered.com/news/2015/03/26/education-dept-keeps-secret-names-colleges-found-be-risky-students-taxpayers

o   https://www.insidehighered.com/news/2015/03/30/education-department-will-release-list-colleges-found-be-risky-students-taxpayers

o   As note, one of the KY institutions, Mid-Continent University, had a federal financial responsibility score of 3.0 at the time it was placed on HCM2.

Another thought: Is the institution you reference also on probation with its accreditor, or about to be?  When an institution that we license is on probation with its accreditor, the institution must notify us and submit an application to us re: change in accreditation status, and we have option to issue a conditional license.

With respect to SARA, we have not yet had an instance where we had a SARA institution placed on HCM2 (we didn't join SARA until 2016, after our two HCM2 institutions closed).  But if we ever do, we would contact NC-SARA and SREB to make sure we were doing what needed to be done.

Hope this helps!

Best,

Sarah Levy, J.D.
Executive Director, Postsecondary Licensing
Kentucky Council on Postsecondary Education
1024 Capital Center Drive, Suite 320
Frankfort, KY 40601

Phone:  (502) 892-3034
Fax:  (502) 573-1535
Email:  sarah.levy at ky.gov<mailto:sarah.levy at ky.gov>

This message may contain sensitive or confidential student and/or academic information and is for the exclusive use of the intended recipient(s).  If you have received this communication in error, please return it to the sender indicating that you received it by mistake and delete the email.

From: S-SARA <s-sara-bounces at lists.onenet.net> On Behalf Of Foster, Kyle
Sent: Monday, October 28, 2019 1:36 PM
To: 's-sara at lists.onenet.net' <s-sara at lists.onenet.net>
Subject: [S-SARA] SARA and HCM2

Good afternoon, S-SARA colleagues.

I hope this Monday is treating everyone well!  I wanted to toss out a question to get everyone's perspectives and hopefully learning something new.

Our office was cc'd on a letter today informing a SARA-participating institution that they have been placed on Heightened Cash Monitoring 2 (HCM2).  The institution is set to renew in January 2020.  Do your states have a procedure when you are notified that a school has been placed on HCM?  If so, do you act immediately or wait for the renewal?

Thanks!

Kyle

Kyle Foster
Assistant Vice Chancellor for Academic Affairs
Oklahoma State Regents for Higher Education
655 Research Parkway, Suite 200 | Oklahoma City, OK 73104<https://urldefense.proofpoint.com/v2/url?u=https-3A__goo.gl_maps_nMc3YG81uo72&d=DwMFAg&c=jvUANN7rYqzaQJvTqI-69lgi41yDEZ3CXTgIEaHlx7c&r=Zi_dVH4hlVseozQpDbd9QEHHLRvumCsDTJk92icxhs8&m=uDwQYGk_vnYUlMflyaPHBZwJFh9VIrQGzGvxzhSat0g&s=QqxfVkkTjLpMYgpma6NCJ0gsgGj-QSBuy2qhjPeeetA&e=>
P: +1 405 225 9163 | F: +1 405 225 9300 | E: kfoster at osrhe.edu<mailto:kfoster at osrhe.edu>
[OK_RegentHighEdu_4c_horz]<https://urldefense.proofpoint.com/v2/url?u=http-3A__okhighered.org_&d=DwMFAg&c=jvUANN7rYqzaQJvTqI-69lgi41yDEZ3CXTgIEaHlx7c&r=Zi_dVH4hlVseozQpDbd9QEHHLRvumCsDTJk92icxhs8&m=uDwQYGk_vnYUlMflyaPHBZwJFh9VIrQGzGvxzhSat0g&s=ClctBHJqTjqbdL89mK6NxkPtkcaZTVwifvuWUaY5tJg&e=>

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