State Authorization Research Projects

Following the recent surge in institutional and campus closures, the growth in online education programs and providers, and increased concerns about educational quality, SHEEO published a white paper exploring the state role in the postsecondary education regulatory triad that includes the federal government and accreditors. In said paper, the authors argue that through the state authorization process, states are the central actors in the higher education public accountability space. While the paper reviews conventional approaches to state authorization and offers recommendations for state agencies to consider, we were unable to find any empirical research on the effectiveness or outcomes of different strategies for state authorization, the process of state authorization, or the experience of individuals involved in state authorization. Without an empirical base of evidence to guide our recommendations, they are not as strong or as specific as they could be.

As such, SHEEO, with generous support from Arnold Ventures, put out an RFP for state authorization research this past November. We received more than 20 excellent proposals. After a blind peer review process, six were selected for funding. The immediate goal of these research projects is to provide states with evidence-based recommendations to improve state authorization. These projects will result in 1) an empirical research paper and executive summary and 2) a corresponding blog post aimed at a more general policy audience.

Funded Research Projects:

Authorization for Alternative Educational Credentials: Evidence from Five States


While career and technical schools have offered short-term credential programs for more than a century, a proliferation of new digital badges, bootcamps, and other so-called micro-credentials have emerged in the past decade. A 2021 Credential Engine report identified approximately 550,000 short-term credentials offered by non-academic organizations. These new programs target adults seeking a streamlined path to in-demand jobs. How states envision their regulatory role in this authorization space remains largely understudied. Using a qualitative, multiple-case design, we provide an overview of how California, Georgia, Illinois, New York, and Washington regulate these entities. Our study combines analysis of key legislative and policy documents and semistructured interviews with 22 leaders from 14 distinct agencies/organizations, including representatives from authorization agencies, other public higher education system offices, and private organizations (e.g., boot camp providers, a digital badge platform provider). Our analyses reveal a number of shared challenges, open questions, and necessary next steps to ensure these credentials are properly understood and regulated moving forward.


Angela Boatman is an Associate Professor of Higher Education at the Lynch School of Education and Human Development at Boston College. Her work focuses on the evaluation of college access and completion policies, particularly in the areas of remediation, financial aid, and community college student success. She has conducted several large-scale studies on the impact of innovations in the delivery of remedial math courses, including the use of instructional technology, on college student outcomes. Her work also explores the timing of remediation, examining the effects of high school-based programs compared to courses offered in college, particularly for students with low incoming test scores. Additional projects include the evaluation of state transfer policies for community college students, and the ways in which principles of behavioral economics can better inform the design and delivery of federal student loan programs. She holds a doctoral degree in Higher Education from Harvard University and a M.P.P in Public Policy and a M.A. in Higher Education, both from the University of Michigan.

Katrina Borowiec is currently a Ph.D. candidate in the Measurement, Evaluation, Statistics, and Assessment (MESA) program at Boston College. Prior to beginning her doctoral degree, she worked full-time in institutional research at Mount Holyoke College and part-time as an academic support specialist and professional tutor for adult learners at Springfield College and Elms College. Her research interests center around the college student experience and student outcomes, in addition to measurement considerations when creating survey instruments for diverse student populations. Katrina has a special interest in studying the experiences and outcomes of students with disabilities and adult learners, two populations she believes are often overlooked in research. She has also completed master’s degrees in higher education from Boston College and survey research methodology from the University of Connecticut.

Breaking Down Barriers: The Impact of State Authorization Reciprocity on Online Enrollment


State authorization, or the approval by a given state for a college to operate within its jurisdiction, is an important part of the regulatory triad. The triad is the three-pronged oversight of higher education that includes the federal government, accrediting bodies, and state governments. State authorization has become more complicated with the rapid expansion of online education that is blurring state geographic boundaries. Colleges seeking to enroll students from numerous states in online programs must obtain authorization in each of those states. The National Council for State Authorization Reciprocity Agreements (NC-SARA) seeks to limit this burden on colleges and expand access to online education to students who may have limited postsecondary options. This study examines the relationship between NC-SARA participation and online enrollments. Using a difference-in-differences approach, we find that colleges joining NC-SARA experience growth in students enrolling in online courses, that early adopters experience larger growths in enrollments, and that enrollments increase over time. We do not find evidence that for-profit institutions, colleges with large pre-NC-SARA online enrollments, or colleges that are highly reliant on online education benefit more than others from joining the agreement.


James Dean Ward is a senior researcher at Ithaka S+R on the Educational Transformation team. His work focuses on federal and state higher education regulatory, funding, and financial aid policies. James earned a BA in economics and history from Cornell University and a PhD in higher education policy from the University of Southern California. James has published and presented work on state financial aid programs, performance-based funding policies, for-profit college regulation, institutional finance, and equity in postsecondary opportunities. In addition to serving as a research assistant in the Pullias Center for Higher Education, James was a postdoc research fellow at the University of Southern California. Prior to graduate school, James conducted research on postsecondary finance at the National Association of College and University Business Officers and served as an institutional researcher at Harvard University. As a higher education consultant for ASR Analytics and Hanover Research, he worked on projects related to institutional aid policies, program development, admissions and recruitment practices, and institutional economic and community impact.

Heidi Booth is a research analyst at the Georgetown University Center on Education and the Workforce where she works on a range of projects relating to higher education and the economy. Previously, Heidi worked as an intern with Ithaka S+R’s Educational Transformation team and as a research assistant for the Community College Research Center at Teachers College. In these roles, she supported projects examining state higher education policy, developmental education, student support services, and equity in postsecondary access and completion. Heidi completed a master’s degree in education policy at Teachers College, Columbia University in 2020. She also holds a bachelor’s degree in political economy from the University of California, Berkeley.

Elizabeth Davidson Pisacreta (Liz) is the associate director for policy and research at Ithaka S+R, where she focuses on increasing college access and success for low-income students and evaluating the implementation of evidence-based strategies to improve student learning outcomes. Liz is a member of the Educational Transformation team. Liz earned a PhD in economics and education at Columbia University where her dissertation focused on the impacts of federal accountability policy on school restructuring and closure. Liz is also the co-founder and Secretary of the Board of ScriptEd, an educational non-profit that provides more than 600 low-income students in 30 NYC high schools with coding instruction and paid internship opportunities in prominent NYC tech firms. Previously, Liz served as the deputy chief strategic officer in the Division of Talent, Labor and Innovation at the New York City Department of Education, where she oversaw policy, communications, and implementation of NYC’s teacher evaluation and development system for more than 75,000 teachers and 1.1 million students. Liz also has experience consulting with various educational organizations on data strategy and analysis, and teacher and school evaluation design and implementation. Liz began her professional career teaching high school math in Philadelphia’s public schools. She holds a bachelor’s degree in economics from the University of Georgia, a master’s degree in urban education from the University of Pennsylvania, and a doctorate in economics and education from Columbia University.

Ben Weintraut is a Ph.D. student at Duke University and a former analyst fellow at Ithaka S+R. Prior to joining Ithaka S+R, Ben worked as an associate economist at the Federal Reserve Bank of Chicago and as a research assistant at the University of Chicago Urban Labs. He holds a master’s degree in public policy from the University of Chicago and a bachelor’s degree in economics and political science from the University of Georgia

An Unsupervised Machine Learning Approach to Developing a Typology of State Authorization Agencies


This project seeks to create a typology of state authorization agencies. First, drawing on various sources, he will construct a dataset which captures germane features of the various state authorization agencies, including such institutional characteristics as staffing, integration with state higher education governance structures, scope of statutory and regulatory authority, and mechanism and scale of agency budgets, among others. To the extent possible, such variables will be collected over time. Utilizing these data, I will apply recent techniques developed in the field of unsupervised machine learning to explore intrinsic and potentially latent clusters within the data, thereby developing categorizations of states based on commonalities in agency characteristics. This project is purposed not only to inform and facilitate future quantitative and qualitative research on the impact of state authorization regimes on various system-level outputs and outcomes, but also to serve as a catalyst for the states in developing peer networks for information sharing and dissemination of best practice surrounding authorization.


Jacob Fowles is an associate professor and the associate director of the School of Public Affairs and Administration at the University of Kansas. His research agenda largely focuses on education finance and policy. Recently, his work has focused primarily on the funding formulas and mechanisms through which states support local education agencies, including school districts as well as institutions of higher education, exploring how such institutional design features and rules may serve to alleviate or reinforce historical patterns of economic disadvantage. Jacob’s research has appeared in such journals as Public Administration Review, the Journal of Policy Analysis and Management, the Journal of Higher Education, and Research in Higher Education, among others. His work has been funded by such organizations as the Spencer Foundation and the Ewing Marion Kauffman Foundation. At KU, Jacob teaches graduate courses in public finance, quantitative research methods, policy analysis, and program evaluation.

The Influence of Federal Policy on State Authorization for Higher Education


State authorization for higher education refers to the required approval from the state government that a college or university obtains to operate as a postsecondary institution in the state. Higher education institutions are not eligible to receive funds through federal student financial aid programs without state authorization. Although the federal government initiated a series of significant reforms on state authorization policy in recent years, little is known about how states respond to federal policy on postsecondary state authorization. This multi-case study analyzed the experiences of five states—California, Illinois, Massachusetts, North Carolina, and Pennsylvania—responding to federal policy on state authorization. Through interviews with 25 individuals and analysis of relevant policy documents, this study found that states learned about federal policy regarding state authorization from a variety of sources, some of which were more closely related to interactive communications with the U.S. Department of Education (ED) than others. States responded to federal policy change by reviewing and updating their state’s authorization processes, by informing institutions about federal policy, and in all states except California, by joining the State Authorization Reciprocity Agreement (SARA). Challenges states have faced when responding to these federal policies include insufficient staff capacity to effectively respond to federal policy, limited communications with ED, complexity of federal regulations, and high costs of compliance. Nongovernmental intermediary organizations have played an important role in many aspects of states’ responses to and implementation of federal policy on postsecondary state authorization.


Rebecca S. Natow is an Assistant Professor of Educational Leadership and Policy at Hofstra University. Dr. Natow’s research has focused on state and federal higher education policies and policymaking processes, including state-level performance-based funding policies for higher education, developmental education policies and practices at public institutions, and the rulemaking process for creating regulations in the U.S. Department of Education. Her work has been published in peer-reviewed, scholarly journals and books. She is author of the book, Higher Education Rulemaking: The Politics of Creating Regulatory Policy, published by Johns Hopkins University Press.

Vikash Reddy is the Senior Director of Policy Research, where he oversees a research agenda that supports equity-focused reforms to California’s higher education systems. Dr. Reddy previously worked as a Policy Analyst at the California Policy Lab at UC Berkeley, and in various capacities at the Community College Research Center and the Center for the Analysis of Postsecondary Readiness at Teachers College, Columbia University. He has worked with state agencies, systems, and colleges for research on performance funding in higher education, reforms in developmental education, and the creation and evaluation of multiple measures placement systems at the State University of New York. Dr. Reddy earned his Ph.D. in Education Policy from Teachers College, Columbia University. He holds a Master’s Degree in Elementary Teaching from Pace University and a Bachelor’s Degree in Government from Dartmouth College.

Victoria Ioannou is currently pursuing an Ed.D. in Educational Policy and Leadership Studies at Hofstra University. There she previously obtained an M.S.Ed. in Higher Education Leadership and Policy Studies. She also holds a B.A. in Psychology from CUNY Queens College. She is currently working as the Alumni Engagement Manager at CUNY Queens College. 

Toward a Consumer Protection Framework to Protect Students From Predatory Practices: A Legal Analysis of Judicial Opinions and State Laws, Regulations


For their project on state authority to improve consumer protection, Hutchens, Fernandez, and Edmondson examined relevant case law and state regulations to better understand the legal frameworks and parameters for states to regulate for-profit providers of higher education. Specifically, they will examine two, inter-related questions: (1) What are the existing state laws and regulations that provide the regulatory and legal framework for state authorization and oversight of for-profit higher education? (2) How have courts interpreted state laws or regulations applied to for-profit higher education providers? Based on their findings, the authors argue that a consumer protection framework to protect students from for-profit higher education should address (a) consumer disclosures to students and potential students; (b) regulating predatory recruitment and marketing practices; (c) and developing capacity to apply general state consumer protection laws to for-profit higher education.


Neal Hutchens serves as Professor and Chair in the University of Mississippi School of Education’s Department of Higher Education. Hutchens earned his Ph.D. from the University of Maryland and his J.D. from the University of Alabama School of Law, where he graduated summa cum laude and was a member of the Order of the Coif. His research focuses on legal issues in higher education. Hutchens was the 2015 recipient of the William A. Kaplin Award from the Center for Excellence in Higher Education Law and Policy at Stetson University College of Law. Hutchens is on the author team—along with William A. Kaplin, Barbara A. Lee, and Jacob H. Rooksby—for the sixth edition of The Law of Higher Education, the leading treatise on higher education law.

Frank Fernandez is Assistant Professor of Higher Education at The University of Mississippi. He studies educational policy and equity issues using quantitative, qualitative, and legal analyses.  He has authored or co-authored articles in The Review of Higher Education, Journal of College Student Development, Higher Education, Educational Policy, and Penn State Law Review, among others.  He was elected as a member-at-large to the executive committee of the Council on Public Policy in Higher Education, which is part of the Association for the Study of Higher Education.

Macey Edmondson is Clinical Assistant Professor of Higher Education and Graduate Program Coordinator for the Department of Higher Education in the University of Mississippi School of Education. Her research interests include legal issues in higher education. She earned her J.D. and Ph.D. at the University of Mississippi. Edmondson previously served as the Assistant Dean for Students at the University of Mississippi School of Law. In 2016, she co-founded the National Association for Law Student Affairs Professionals (NALSAP) and was elected as President of the organization in 2019. She also serves on the Mississippi Advisory Committee to the U.S. Commission on Civil Rights.

State Authorization Landscape and Process: An inventory, classification, and analysis


Despite the longstanding and central role states play in the regulatory triad, we have much to learn about how states authorize postsecondary education programs, how these processes vary between states, and why states take particular approaches to authorization. Our project aims first to describe and to classify the state authorization landscape by conducting a 50-state inventory of state authorization efforts. We will then select 3-5 states to examine in greater detail to understand the process of state authorization. Our analysis will employ principal-agent theory to examine the relationship between state authorizing agencies and postsecondary institutions, including the monitoring and oversight efforts. Based on our findings, SHEEO agencies may consider other approaches that align better with their policy objectives and specific state context. Understanding how each state authorizes (and reauthorizes) postsecondary institutions is vitally important for improving the state’s role in the regulatory triad, maintaining quality, and protecting consumers.


Erik Ness is associate professor of higher education and graduate coordinator in the Institute of Higher Education at the University of Georgia. Previously, he served as assistant professor and coordinator of the Higher Education Management program at the University of Pittsburgh and as a policy analyst for the Tennessee Higher Education Commission. Ness teaches and conducts research on higher education politics and policy. His research agenda primarily considers the public policymaking process, specifically the political dynamics associated with state-level higher education governance and policy. His recent work examines research utilization—the extent to which policymakers rely on research evidence to craft policy—in the adoption and implementation of various state higher education policy initiatives such as college completion policies, funding strategies, and student financial aid programs.

Sean Baser is a doctoral student in the Institute of Higher Education at the University of Georgia. He also serves as a graduate research assistant in the Research & Policy Analysis division of the Board of Regents of the University System of Georgia. Baser’s research centers on higher education politics, policy, and governance. His research explores the higher education policymaking process at the state and institution levels, from policy formulation through implementation and evaluation. Baser is particularly interested in how interest groups and intermediary groups (namely, philanthropic foundations and state agencies) affect education policy, scholarship, and practice. His recent research has analyzed dual enrollment policies as well as the role of state community college governance, “dark money,” and a host of other factors in education finance.

Matt Dean is a Ph.D. student at the Institute of Higher Education at the University of Georgia. He holds a master’s degree in higher education administration from Louisiana State University and a bachelor’s degree in political science from Clemson University.

Investigating Factors Associated With College Openings and Closures: The Role of State Authorization Policies


Between 2016 and 2021, an average of 20 postsecondary institutions, most of which were for-profit institutions, closed each month. Though these closures affected approximately 500,000 students, we know surprisingly little about the factors driving this recent institutional instability and how state policies can better regulate higher education to protect students from predatory institutions and low-quality postsecondary credentials. This paper has two main goals: 1) documenting variation in the stringency of state authorization policies and the landscape of institution openings and closures, and 2) investigating factors that may be correlated with openings, closures, and stringency. We find that the stringency of authorization policies varies greatly across states, but we find no significant associations between our stringency measure and state-level demographic, economic, educational, and political characteristics. Using an institution-level dataset, we find that for-profit institutions are more likely to open and more likely to close relative to nonprofit institutions, but we find no evidence of a consistent association between stringency and openings or closures. Using a state-level dataset, we find no association between stringency and total closures or for-profit closures (both as a count and a percentage of total or for-profit institutions, respectively). We do, however, find a negative relationship between stringency and number of total openings, suggesting that fewer openings occur in states with more stringent authorization policies. This evidence may help capacity-constrained state authorization offices advocate for additional resources to fulfill their role of protecting students from predatory institutions.


Madison Dell is pursuing a Ph.D. in economics of Education at Stanford University’s Graduate School of Education. She is a recipient of the Institute of Education Sciences Predoctoral Training Fellowship in Quantitative Education Policy Analysis and the Stanford Graduate Fellowship in Science and Engineering. She earned a bachelor’s degree from the University of Tennessee at Chattanooga and a master’s degree from Louisiana State University. Before coming to Stanford, Madison worked at the University of Tennessee at Chattanooga and at the Tennessee Higher Education Commission. Her research interests lie at the intersection of higher education, economics, and public policy, including topics such as the impact of state and federal higher education policy on student outcomes and optimal allocation of financial aid and institutional resources to support college access and completion. Madison aspires to do work that improves students’ access to and success in higher education and empowers policymakers and practitioners to create environments in which students can thrive.

Jason Lee joined SHEEO in August 2019. He currently serves as a senior policy analyst, working out of SHEEO’s Boulder office, where he supports the association’s research enterprise. His prior research focuses on evaluating federal, state, and institution-level policies and programs to determine where in the postsecondary pipeline students struggle to succeed. This work has been published in a number of outlets including the Journal of Higher Education, the Journal of Human Resources, and the Higher Education: Handbook of Theory and Research. Dr. Lee has over 10 years of experience working in education, including time spent as a K-12 teacher, working as a campus administrator in a variety of settings, and, finally, working as a quantitative researcher for two state higher education agencies in Tennessee. He earned his Ph.D. from the University of Georgia’s Institute of Higher Education, his master’s degree from Indiana University of Pennsylvania, and his bachelor’s degree from Slippery Rock University.

Dustin Weeden joined SHEEO in October 2017 as a senior policy analyst, working out of SHEEO’s Boulder office. His primary focus is on SHEEO’s analysis of the capacity of state postsecondary data systems and their effective use. Mr. Weeden’s research interests include state higher education policy related to finance, governance, affordability, student borrowing, and the commercialization of research. Prior to joining SHEEO, he served as a senior policy specialist with the National Conference of State Legislatures. In this role, Mr. Weeden coordinated the Legislative Education Staff Network, tracked and analyzed state higher education legislation, and authored policy briefs, research reports, blog posts, and State Legislatures magazine articles on a wide range of topics including outcomes-based funding, affordability, tuition policy, financial aid, and student borrowing. Mr. Weeden is a doctoral candidate in higher education at the University of Iowa. He also holds an M.P.P from the University of Denver and a B.A. in history and political science from Kansas State University.

State Authorization Research: Findings, Themes, and Future Directions


The demand for greater consumer protection in higher education has increased in recent years, perhaps due to a number of high-profile institution closures and lawsuits alleging fraud perpetrated by postsecondary institutions (e.g., Butrymowicz, 2020; Folley, 2018; Wong, 2015). The “regulatory triad” consists of three entities that share responsibility for protecting students in higher education: the federal government, accrediting bodies, and state governments (Hegji, 2019; Kelchen, 2018). State governments play a crucial role in consumer protection since they are empowered to decide which institutions may operate in the state through a process called state authorization. Through the authorization process, states request information and evidence that institutions will prepare students with high-quality education to develop necessary skills for labor market success. Though authorization is incredibly important in keeping bad actors out of the higher education market, relatively little research has explored the process of state authorization and its impacts on states, institutions, and students. This paper series, supported by Arnold Ventures and coordinated by the State Higher Education Executive Officers Association (SHEEO), aims to begin filling the gap in the literature with seven papers. These papers use diverse methods to answer novel questions and provide evidence about different aspects of state authorization. The introduction and summary proceed as follows: I provide a brief overview of each paper, then identify key themes among the papers, and conclude with a discussion about opportunities for future research in this space.


Madison Dell is pursuing a Ph.D. in economics of Education at Stanford University’s Graduate School of Education. She is a recipient of the Institute of Education Sciences Predoctoral Training Fellowship in Quantitative Education Policy Analysis and the Stanford Graduate Fellowship in Science and Engineering. She earned a bachelor’s degree from the University of Tennessee at Chattanooga and a master’s degree from Louisiana State University. Before coming to Stanford, Madison worked at the University of Tennessee at Chattanooga and at the Tennessee Higher Education Commission. Her research interests lie at the intersection of higher education, economics, and public policy, including topics such as the impact of state and federal higher education policy on student outcomes and optimal allocation of financial aid and institutional resources to support college access and completion. Madison aspires to do work that improves students’ access to and success in higher education and empowers policymakers and practitioners to create environments in which students can thrive.


David Tandberg, senior vice president of policy research and strategic initiatives