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Department of Education Issues Dear Colleague Letter on State Authorization

June 26, 2015 —The Department of Education June 19 issued a Dear Colleague Letter (DCL) reminding postsecondary institutions that regulations on “physical presence” state authorization are effective July 1, 2015. The DCL states, “After that date, postsecondary institutions are expected to demonstrate compliance with the requirements; institutions that are not compliant with the State authorization regulations under 34 CFR 600.9(a) and (b) may lose their eligibility to participate in Title IV programs.”

These regulations will take effect July 1, 2015, despite the vacated Department of Education rule on “distance education” state authorization. Addressing institutions that operate across state lines, the guidance states, “To demonstrate that an institution is legally authorized to operate in another State in which it has a physical presence or is otherwise subject to State approval or licensure, the institution must demonstrate that it is legally authorized by the other State in accordance with § 600.9.”

Of importance to medical school clinical rotations, additional guidance notes, “The Department is continuing its policy that students attending one or more locations of an institution [including internships and externships] where the students cannot complete more than 50 percent of a program are considered to be enrolled at the main campus of the institution and these locations need not be listed on its [Application for Approval to Participate in Federal Student Financial Aid Programs (E-App)] or included on its [Eligibility and Certification Approval Report (ECAR)].”

However, the guidance also cautions that “State requirements may require an institution to obtain approval of such sites, and the Department may take that information into consideration when determining whether the institution meets applicable State requirements.”

The AAMC has prepared a summary resource  for medical schools regarding state authorization’s impact on clinical rotations and the State Authorization Reciprocity Agreement (SARA).


Matthew Shick, JD
Director, Gov't Relations & Regulatory Affairs
Telephone: 202-862-6116


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806