Policy - Determination of Student Location

This is a summary of the Policy on Determination of Student Location. Click here to view the official policy in its entirety in the UW-Madison Policy Library. 

Overview

• The State Authorization Reciprocity Agreement (SARA) is an agreement between member states to offer distance education programs to students in other SARA member states. 
• In 2020, the U.S. Department of Education revised the federal regulations initially established in 2016 for institutions that offer distance education.
• Adherence to the new federal regulations, which go into effect 1 July 2020, is a condition of Title IV eligibility (i.e., the ability to offer federal student aid). 
• One important change to the 2020 regulations is the requirement for institutions to determine and track where their students are located (i.e., where they lay their head) as opposed to state of residency. 

Tracking Student Location

• Requires institutions to determine in which states students are located 
• Used in part for the purpose of issuing state-specific disclosures about educational preparation for certification/licensure in the state where the student is located
• Institutions must determine each student’s location (i.e., state):
  1. At the time of the student’s initial enrollment in an educational program, and
  2. Upon formal receipt from the student of information about a change in the student’s location
• Rule allows each institution to establish its own procedure for determining state of location, but institutions must:
  1. Have documented process/procedures on how the location is determined,
  2. Have a documented change-of-address process for all students, and
  3. Consistently apply policies and procedures regarding student location to all students, including students enrolled in on-ground programs

UW–Madison Policy on Determination of Student Location

UW–Madison will determine the location of a student for purposes of providing accurate professional licensure disclosures in the following way. The “Local Address” field within the university’s Student Information System (SIS) will be recorded as each student’s location. The university defines the Local Address as, “A physical address where a student currently or will live and/or frequently stay during the time they will be taking classes for the upcoming term. It is a place of residence where someone would be most likely to find the student; where the student puts their head down at night.”

All degree-seeking students provide and review their Local Address as part of the Pre-Enrollment Checklist process. New incoming undergraduates (freshmen and transfer students) complete the Pre-Enrollment Checklist prior to the Student Orientation, Advising, and Registration (SOAR) program. New incoming graduate and professional students complete the Pre-Enrollment Checklist before they are eligible to enroll in their first semester of studies. Continuing students (all programs, all levels) complete the Pre-Enrollment Checklist prior to each fall and spring enrollment period. The Local Address field is a required component of the Pre-Enrollment Checklist and all students at all levels must review and verify or update the address. In addition, students can update their Local Address at any time via the Student Center. Students who provide or update their Local Address during the Pre-Enrollment Checklist process have that Local Address effective-dated at the start of the term. A student-initiated update via the Student Center is effective-dated with the date of the change. (Note: Guest students and senior auditors are excluded from the student location reporting requirement.)

Data, Reporting, and Disclosure re. Professional Licensure

Data on student location will be made available to programs that lead to professional licensure by the Office of the Registrar at the beginning of each fall and spring term. Per these federal regulations, programs will be required to make an individual written disclosure to prospective and current students if the program does not meet the educational requirements for initial licensure/certification in the student’s state of location, or if the program has not made a determination regarding whether the program meets the educational requirements for initial licensure/certification.

Policy History

Approved: University Academic Planning Council, 21 May 2020