Massachusetts SARA FAQs & Resources

This FAQs & Resources webpage is intended for SARA contacts at institutions of higher education (IHEs) that are interested in applying to participate in Massachusetts SARA or are currently in the process of renewing institutional participation in Massachusetts SARA. For questions in general regarding Massachusetts SARA, please visit the DHE’s SARA webpage.


Frequently Asked Questions

What is the National Council for State Authorization Reciprocity Agreements (NC-SARA)?

NC-SARA is the national organization that coordinates SARA Regional Compacts, SARA Portal Entities, and SARA-member institutions across the United States. Your institution will most likely only need to interact with NC-SARA regarding deadlines associated with your renewal application, payment of NC-SARA fees, and the annual reporting of student enrollment  and out of state learning placement (OOSLP) data. Most questions regarding participation in Massachusetts SARA can be directed to DHE’s SARA Team, but if you have any questions specific to NC-SARA, please visit https://www.nc-sara.org

How much does it cost to participate in Massachusetts SARA?

Institutions that wish to participate in Massachusetts SARA must first pay a fee to DHE. The fee will vary depending on the most recently published final release FTE of that institution as reported in IPEDS. Once DHE has determined that an institution is eligible to participate in Massachusetts SARA, the institution will then pay a fee to NC-SARA, which is also based on the FTE of the institution as reported in IPEDS. Each fee—one to DHE and one to NC-SARA—are due every year that the institution participates in Massachusetts SARA.

How does an institution remit payment of the Massachusetts SARA fee to DHE and NC-SARA?

Payment of the Massachusetts SARA fee is required to be made in the form of a check mailed or couriered, made payable to DHE, in accordance with these instructions. After DHE deems an institution eligible to participate in Massachusetts SARA, the institution’s SARA contacts will receive an email directly from NC-SARA for instructions on how to remit payment to NC-SARA.

How long does it take for DHE to process payment of the Massachusetts SARA fee?

Electronic payments are recorded instantaneously when institutions submit payment via the MA-SARA Portal. DHE will review applications for completeness when both payment information and the application have been submitted, even if the payment status is still pending. Please note that it may take additional time after initial authorization for funds to transition from a pending status to being fully settled. If you have any questions regarding the status of an institution’s Massachusetts SARA fee payment, please reach out to the DHE’s SARA Team via email at SARAInquiries@dhe.mass.edu or by phone at 617-994-6910.

Do institutions need to apply to both NC-SARA as well as DHE to participate in SARA?

No. NC-SARA provides institutional applications on its website. Most SARA member states and territories use these applications and attach additional addenda to NC-SARA’s applications. However, in Massachusetts, DHE provides an online application that institutions are required to use instead. The online Massachusetts applications incorporate NC-SARA’s application fields already, so institutions do not need to fill out any applications provided by NC-SARA. The Massachusetts SARA applications have required fields in addition to those required by NC-SARA, i.e. the Massachusetts addendum, therefore all Massachusetts institutions must use the online applications provided by the DHE because NC-SARA’s applications do not contain all of the required fields for Massachusetts institutions.

Which entity is responsible for determining an institution’s eligibility to participate in SARA?

The DHE in its capacity as the State Portal Entity (SPE) for the Commonwealth of Massachusetts is the sole entity responsible for determining an institution’s eligibility to participate in Massachusetts SARA. Institutions apply to the DHE, not NC-SARA, to participate in SARA because NC-SARA does not have the authority to determine an institution’s eligibility to participate in SARA.

How long does it usually take for DHE to evaluate institutional applications for eligibility to participate in Massachusetts SARA?

Since the DHE began accepting institutional applications on June 18, 2018, application processing times have remained steady. On average, institutional applicants have received a final determination of eligibility within 2–4 weeks, depending in part upon the completeness of the initial Massachusetts SARA application submission and the volume of applications DHE has received.

How are student complaints filed and processed under Massachusetts SARA?

Students currently living in states outside of Massachusetts that are enrolled in distance education (online) courses or programs offered pursuant to an institution’s participation in Massachusetts SARA may file a SARA complaint with DHE after exhausting the institution’s complaint procedures. The DHE Student Complaint Policy explains how the DHE will forward SARA complaints to Massachusetts SARA institutions in the event that a SARA complaint is filed. DHE is responsible for reporting to NC-SARA the number of SARA complaints that are received against each Massachusetts SARA institution on a quarterly basis. If you have any questions, please visit the DHE SARA Complaints page, or contact the DHE SARA Team.

Why are institutions required to submit copies of Disaster Recovery Plans to DHE as part of the Massachusetts SARA initial and renewal applications?

DHE requires institutions to submit copies of Disaster Recovery Plans to ensure that the institution has adequate plans in place to ensure the preservation of student records in the event of institutional closure. These plans must affirm the institution’s commitment to follow both the institution’s accrediting body’s standards for institutional closure (e.g. NECHE’s Considerations When Closing an Institution of Higher Education) and the DHE’s Notice of Closure Guidelines 

The DHE recognizes that each institution is different and may have different or multiple plans, procedures, and/or policies in place that are related to the protection of student records in the event of institutional closure. For example, Disaster Recovery Plans may also exist under other names like Continuity of Operations Plans or Institutional Closure Procedures/Policies. Any form of these plans is acceptable for Massachusetts SARA purposes as long as the copy provided has been incorporated into an existing institutional Disaster Recovery Plan, Continuity of Operations Plan, or Institutional Closure Procedure/Policy. In the alternative, an affirmation in writing from the CEO/President or CAO/Provost of the institution that certain procedures will be followed in accordance with the institution’s accrediting body’s standards for institutional closure and the DHE’s Notice of Closure Guidelines will also be accepted.

Why are institutions required to provide an FTE figure in the Massachusetts SARA initial and renewal applications?

Both the Massachusetts SARA fee and the NC-SARA fee are assessed on an institution’s total full‐time equivalent (FTE) enrollment as submitted to the Integrated Postsecondary Education Data System (IPEDS) each fall as 12‐month FTE enrollment. For these purposes, the relevant figure is the most recently published final-release FTE.

What is the Financial Responsibility Composite Score (FRCS)?

The FRCS is a score typically calculated by the United Stated Department of Education (US-DOE) to determine an institution’s financial standing for programs like federal student aid. These scores are available to the public. US-DOE provides calculations of this score to institutions via institutional correspondence and publicly at the URL above to Title IV participating institutions. Because the FRCS Score is the only nationwide metric for analyzing an institution’s financial standing, NC-SARA requires non-public institutions participating in Title IV to report this score on SARA applications to demonstrate institutional financial stability. Public institutions are presumed to be financially stable for the purpose of participation in Massachusetts SARA. In general, institutions with FRCS Scores of 1.5 or above are also presumed to be financially stable for the purpose of participation in Massachusetts SARA. Institutions with an FRCS Score between 1.0 and 1.49 may still apply to participate in Massachusetts SARA but are required to submit additional documentation of financial stability. Even where an institution submits such additional documentation, however, the Commissioner reserves the right to deny eligibility to an institution with an FRCS Score between 1.0 and 1.49 if the institution is not financially stable. (See 610 CMR 12.03(f)(1)).

NC-SARA policy mandates that the FRCS score used be the one most recently published by US-DOE (currently for FY2017-18) or a later score communicated to the institution directly by US-DOE in a letter or email. The DHE does not have the discretion to accept scores calculated by an institution’s independent auditor or accountant in lieu of the most recently published score.

If your institution does participate in Title IV or for any other reason does not have an FRCS Score calculated by US-DOE, please contact us.

What are acceptable forms of documentation for institutional domicile?

Documentation of domicile is required for the DHE to verify the legal name and address of each Massachusetts SARA applicant. Massachusetts public institutions may submit either an Internal Revenue Service (IRS) certification letter (e.g. Form 6166) or a copy of the institution’s enabling statute(s) (e.g., G.L. c. 15A § 5). All other institutions may submit either the first page of the institution’s most recent 990 tax form or the most recent Articles of Amendment/Articles of Incorporation filed with the Massachusetts Secretary of the Commonwealth. Institutions that do not have Articles on file with the Secretary of the Commonwealth (typically, those chartered by the Massachusetts legislature prior to 1943) may submit a copy of their legislative charter. Please note, however, that institutions chartered by the legislature may still need to provide its most recent 990 tax form if the institution’s legal name has changed since its incorporation.

How do I know if my institution is offering courses or programs that customarily lead to professional licensure, and why does it matter?

Courses or programs leading to professional licensure have special requirements under both NC-SARA Policy (See SARA Manual Section 5.2 and 34 C.F.R. § 668.43 (July 1, 2020)) and Massachusetts SARA Regulations. (See 610 CMR 12.03(2)). Courses or programs that customarily lead to professional licensure are typically required as prerequisites in a student’s pursuit of a professional license from a governmental licensing entity. Some examples of programs that customarily lead to professional licensure are nursing and education programs, both of which require students to sit for professional licensure exams prior to practicing as a nurse or teacher in a certain jurisdiction. 

If the course or program an institution aspires to offer online to out-of-state students customarily leads to professional licensure, the institution is required to notify students whether or not the course or program meets the professional licensure requirements of the student’s home state through general disclosures on institutional webpages (e.g. charts and program profiles), and direct disclosures through email if the program does not meet the student’s home state’s requirements or the institution has not yet made a determination whether the program meets the student’s home state’s requirements. If an institution has not yet made a determination whether or not its courses or programs have met the requirements of a student’s home state, then at an absolute minimum the institution must provide contact information for the appropriate agency within the student’s home state, and advise the student to determine whether the course or program meets the student’s home state’s requirements for licensure. 

Note: For the purposes of the Massachusetts SARA applications, institutional applicants should prepare draft direct disclosure templates, as well as general disclosure webpages, for submission as attachments to the Massachusetts SARA institutional applications.

Please also keep in mind that some states have additional legal and regulatory requirements for courses or programs that customarily lead to professional licensure that are not superseded by an institution’s participation in Massachusetts SARA. In some states, Massachusetts SARA institutions will still need additional approvals from governmental licensing entities outside of Massachusetts prior to offering courses or programs to students located outside of Massachusetts. Institutions are urged to reach out to other states’ licensing entities prior to offering courses or programs that customarily lead to professional licensure to students located outside of Massachusetts to avoid any disruptions in delivery of distance (online) education to out-of-state students enrolled pursuant to participation in Massachusetts SARA.

NC-SARA has additional information regarding professional licensure here:


Resources

April 14, 2022 DHE & NEBHE Virtual Meeting on Professional Licensure Disclosures

Below please find slides and a link to the recorded virtual meeting DHE and the New England Board of Higher Education (NEBHE) co-hosted on April 14, 2022 for Massachusetts SARA institutions on professional licensure disclosures.

Application Prep Checklists

These checklists provide a list of the documents required for submission of the Massachusetts SARA Initial/Renewal applications—they can be used as a tool to assemble institutional materials prior to uploading the application.

Example Materials
Institution Examples

* Colleges and universities that have been granted the authority to grant degrees by the BHE fall under the BHE’s purview. Students located in Massachusetts attending courses at these institutions may file a consumer complaint with the DHE if their concerns are not addressed at the institutional level.

** Not all colleges and universities in the Commonwealth of Massachusetts are subject to the BHE’s degree-granting authority and oversight. Some institutions received degree-granting authority directly from the legislature prior to establishment of the BHE in 1943, or otherwise do not fall under the BHE’s purview. Students located in Massachusetts attending courses at these institutions may file a consumer complaint with the Attorney General’s Office (AGO) if their concerns are not addressed at the institutional level.  


Who should I contact about Massachusetts SARA?

The DHE’s SARA team can be reached via phone at 617-994-6910 and by email at SARAInquiries@dhe.mass.edu. While our team continues to work remotely, constituents may experience delays in response to voice messages. If your voice message has not received a response, please follow up vie email at SARAInquiries@dhe.mass.edu.

Note: all application materials must be submitted via the online applications instead of using NC-SARA’s PDF application forms. Please do not mail Massachusetts SARA institutional applications to the DHE.

Last updated: April 12, 2021