Out-of-State Activities

Policy for Out-of-State Activities

UTEP is committed to complying with rules and regulations regarding the operation of higher education institutions in every state in which it enrolls students. This practice, known as State Authorization, relates to all out-of-state activities ranging from fully online programs to experiential learning activities in face-to-face courses and many other trigger activities in between. Extended University will review and complete authorizations for all UTEP programs with out-of-state activities. We can only do this with the cooperation of all academic units with out-of-state activities, including those without UTEP Connect fully online programs.


  • State Authorization: The authorization of an institution in the states and territories where it provides trigger activities
  • Trigger Activities: Out-of-state activities that require trigger application and/or reporting. These may include but are not limited to credit-bearing educational activities, out-of-state faculty, and/or related business activities such as marketing and advertising.
  • Unit: A college, school, department, office, or institute/center
  • NC-SARA State: A state or US territory that is a member of the NC-SARA organization
  • Non-NC SARA State: A state or US territory that is not a member of the NC-SARA organization


  • UTEP is a member of the State Authorization Reciprocity Agreement (SARA) and can, therefore, conduct certain activities in other SARA member states without additional authorization from those states. However, not all out-of-state activities are covered by the SARA agreement. Additionally, UTEP must report information annually to SARA on student enrollment and experiential learning. Extended University and UTEP Connect rely on various units to provide information for SARA reporting and out-of-state activity reporting.
  • In Non-SARA states, UTEP must first obtain approval or exemption from the state in order to offer certain trigger activities.
  • New authorization may be needed when a new activity or program begins in both a SARA state as well as a non-SARA state.
  • Regardless of SARA membership or state approval, units may be required to obtain approval from a professional licensing board in each US territory when the educational program is in a field which requires licensure. This may be true of both pre- and post-licensure programs. Units are responsible for seeking professional licensing board approvals in both NC-SARA states and non-NC-SARA states and providing evidence of approval to Extended University/UTEP Connect.

Extended University Responsibilities:

  • We will educate units regarding state authorization requirements related to conducting trigger activities out of state.
  • We will also seek necessary approvals to operate in US territories and states other than Texas.The required disclosures and state status will be posted and kept current on UTEP Connect’s website. We will also report any changes in approval status to enrollment counsellors and admissions.   
  • We will collect, analyze and report aggregate data to fulfill annual reporting requirements for SARA and non-SARA states.

 Unit Responsibilities:

  • Units are responsible for reporting any and all out-of-state activities and any other applicable information to Extended University as requested, and at least once per term. Units will educate their teams regarding out-of-state activities and the need to coordinate with Extended University. 
  • Units will disclose professional licensing board status to students. Units must seek all professional licensing board approvals in all states and submit the approval letters to Extended University.
  • Activities that must be reported to Extended University include:
    • Maintaining a physical location, facility or instructional site including servers, equipment, or administrative offices
    • Recruiting students through marketing, advertising, or events including online and on the ground
    • Employing full-time and/or adjunct faculty
    • Conducting either required or optional instructional activities such as clinicals, labs, practica, internship or externships (where students meet face-to-face)
    • Requiring students to physically meet in an out-of-state location for instructional purposes
    • Entering into contracts or agreements to provide services such as proctored exams to students
    • Partnering with educational institutions
    • Preparing students to sit for a professional license or certification exam
    • Providing either pre- or post-licensure education in a field that requires approval from a professional licensing board
    • Completing field research