To Protect Students from Unfair Practices, 25 Attorneys General Advise National Council for State Authorization Reciprocity Agreements That Critical Reforms Are Necessary

BALTIMORE — Attorney General Frosh today led a bipartisan coalition of 25 attorneys general in a letter to the National Council for State Authorization Reciprocity Agreements (NC-SARA) urging it to institute stronger consumer protection policies for the over 3 million students enrolled in distance education courses offered by its 2,276 participating institutions.

NC-SARA provides leadership over reciprocity agreements joined by 49 states, the District of Columbia, Puerto Rico, and the Virgin Islands, and it controls the minimum standards and policies to which participating institutions must adhere.  The attorneys general, citing examples of misconduct by schools participating in NC-SARA, including unscrupulous recruitment and enrollment practices by a for-profit school operating in Maryland, express concerns that NC-SARA’s current policies do not adequately protect students against the unique risks that arise from distance learning, including unfair and deceptive admissions and financial aid practices.  The attorneys general recommend NC-SARA improve its policies to provide critical student protections, including:

  • Removing language in its Policy Manual that prohibits states from enforcing their higher education consumer protection laws and instituting meaningful consumer protection standards that participating schools must follow;
  • Improving its procedures to protect current and prospective students at institutions with issues related to consumer protection or financial stability; and
  • Reconstituting its board of directors so that at least a majority of its membership is reserved for member states and territories and additional individuals with consumer protection expertise, such as state attorneys general, are included.


“The COVID pandemic has brought about unique challenges for students, especially in the delivery of education,” said Attorney General Frosh. “As an organization that oversees national standards in distance learning, NC-SARA has a responsibility to ensure distance-learning students are protected to the fullest extent possible from unfair and deceptive practices.”

The attorneys general are committed to working with NC-SARA and appreciate its willingness to engage in a dialogue on these important issues.

Joining Attorney General Frosh in today’s letter are the attorneys general of Colorado, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Iowa, Maine, Massachusetts, Michigan, Minnesota, Nebraska, Nevada, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Tennessee, Vermont, Virginia, Washington, and Wisconsin.