2.2.3 Location and Attestation

Responsible Position

Vice President of Academic and Student Affairs

RELATED ITEMS

Minnesota State Board Policy

• Minnesota State Board Policy 2.2 State Residency

Minnesota State System Procedure

• Minnesota State Board Procedure 2.2.1 State Residency Reclassification
• Minnesota State Board Procedure 2.2.2 U.S. Military Members, Spouses, and Dependent Children

Minnesota Statutes

• Minnesota Statute 135A.043, Resident Tuition

Other

• NC-SARA

PROCEDURES

Purpose

This procedure addresses how Alexandria Technical and Community College complies with NC-SARA requirements regarding the determination of student location and the collection of attestations for students enrolling in programs that may not meet professional licensure requirements in their U.S. state or territory where the student is physically located.

Determining Student Location

At the time of a student's initial enrollment in an educational program, the institution must determine and document the student's physical location. This refers to where the student is physically located at the start of the program—not necessarily their permanent address. For military-connected students, see ATCC Procedure 2.2.2.

The institution must update a student's documented location upon formal receipt of information from the student or when the institution obtains reliable information indicating that the student has relocated. Acceptable documentation includes written notification from the student, updated address forms, or other verifiable records.

This updated location may trigger new regulatory obligations, including the need for a revised attestation.

Students who fail to provide required location information or updates may be prohibited from enrolling in distance education courses until compliance is achieved.

Definitions

Attestation:

An attestation is a formal, written statement in which a student affirms and verifies the accuracy of specific information required for regulatory compliance. For NC-SARA and professional licensure purposes, an attestation serves as the student's signed acknowledgment that they understand the program's professional licensure limitations in their current state or territory of location and confirm their intent to seek employment or licensure in a specific U.S. state or territory where the program meets educational requirements. The attestation must be signed dated, and maintained as part of the student's official academic record.

Initial Enrollment in an Educational Program

The point at which a student first enrolls in and registers for classes that count toward the program's credential in a specific educational program offered by the institution. This is used to establish the student's physical location for purposes of federal, state, and NC-SARA regulatory compliance.

Location

For purposes of federal regulation and NC-SARA, "location" means the state in which a student is physically situated when engaging in educational activity at the time of initial enrollment in an educational program, and upon any formal notification of a change in state.

NC-SARA (National Council for State Authorization Reciprocity Agreements):

NC-SARA is a national nonprofit organization that oversees the State Authorization Reciprocity Agreement (SARA), an interstate compact that establishes uniform standards for delivering postsecondary distance education across member states, districts, and territories. Through NC-SARA, institutions in participating states are permitted to enroll students located in other SARA member states without seeking separate state-by-state authorization, except in cases involving professional licensure programs. NC-SARA supports consistent regulatory oversight, protects students, and simplifies compliance for institutions participating in interstate distance education.

State Authorization

State authorization refers to the legal approval required for an institution to enroll students located in each state in distance education or other educational activities. ATCC participates in this process through NC-SARA, which allows the college to offer most online programs to students located in participating states, subject to program-specific licensure requirements

Attestation Requirement for Licensure Programs

Students enrolling in programs designed to lead to professional licensure or certification may be impacted by differing state requirements. If a student is located in a state where the institution has determined that the program does not meet the educational requirements for licensure, the student may only enroll if they complete an official attestation.

Purpose of Attestation

The attestation serves as a formal acknowledgment that the student understands the program's limitations in their current state and affirms their intent to seek employment in a different state where the program does meet the licensure requirements.

Attestation Process

• The attestation must be provided in writing, signed, and dated by the student before the student enrolls in the licensure program (and before any related financial commitment, as applicable). A link to the official ATCC Licensure Attestation Form will be maintained on the Registrar's website and referenced in program admission communications.
• The statement must identify the specific U.S. state or territory where the student intends to seek employment or licensure and explicitly affirm that the institution's curriculum satisfies the professional licensure requirements for that location.
• Students who do not provide the required attestation may not enroll in the program if they are located in a non-compliant state.

Documentation and Storage

All attestation forms must be:

• Collected and reviewed by the Registrar's Office or designated NC-SARA compliance officer
• Maintained in the student's official academic record
• Available for review during NC-SARA audits or institutional compliance checks

If a student changes location to a new state where the program still does not meet licensure requirements, a new attestation may be required.

Ongoing Monitoring and Reporting

The institution must:

• Keep accurate and up-to-date records of student physical locations at enrollment and upon any relocation
• Track which students have submitted attestations and in what context
• Report student location data and out-of-state learning placements (OOSLP) annually as required by NC-SARA

Professional Licensure Disclosures

In addition to collecting attestations when applicable, the institution will provide professional licensure disclosures as required. Public disclosures (general program disclosures) will be maintained in a central location on the college website and kept current by the responsible office. Direct disclosures (individualized notices) will be provided to a student in writing based on the student's documented state or territory of location and will be delivered prior to enrollment in the program (and before any related financial commitment, as applicable).

These records support both internal accountability and compliance with the NC-SARA annual reporting cycle (May 15-June 15).

Oversight and Responsibility

The Registrar or designated NC-SARA compliance officer is responsible for ensuring that:

• Location is verified and documented for each new enrollee
• Attestations are requested, reviewed, and retained as required
• Any change in student location is followed by appropriate compliance review
• Procedures are reviewed regularly and updated to reflect policy changes