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


The knowledge economy of the past decade has seen the proliferation of short-term, career-oriented postsecondary educational offerings such as badges, bootcamps, and other micro-credentials. The rapid expansion of alternative credentials has led to a staggering number of programs. A 2019 report from the non-profit Credential Engine cited 315,067 credentials being offered from non-academic organizations, including digital badges and online course-completion certificates, with 7,132 additional credentials being granted by MOOC providers. Regulating these programs is unfamiliar to many state agencies whose processes are based on traditional models of education. In an effort to understand how states currently do or do not regulate these entities and how they envision their role in regulating non-traditional educational credentials, we propose an in-depth case study of five states, along with a subsequent cross-case analysis of the findings. We will examine the regulatory approval process, including state consumer contracts and legislative rules, as we develop a structural framework for quality assurance that considers the wide variety of programs and political contexts that exist. The goal for this research is to provide the field with cross-state comparisons that facilitate the sharing of lessons and best practices across the agencies. The practices will inform state authorization going forward, which should, in turn, improve outcomes for students entering micro-credentialing programs.


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.

State Authorization, Online Enrollments, and Heterogeneous Growth


State authorization, as one facet of the higher education regulatory triad, plays an important role in determining which institutions can legally operate within a given state’s jurisdiction. The growth of online education has resulted in a cooperative approach among states to grant reciprocal authorization in an effort to lower regulatory burdens. In this study, we assess the impact of state participation in the State Authorization Reciprocity Agreement (SARA). The agreement, which now extends between 49 states and nearly 2,000 institutions, is intended to remove barriers to postsecondary opportunities by standardizing the authorization procedure for degree-granting institutions operating online learning programs in multiple states. This study uses a difference-in-differences design to estimate the effects of SARA participation on online enrollments. We examine how these effects vary by institutional type and capacity for online learning, as well as the potential that early adopters may benefit the most. The findings from this study will serve to inform policymakers of the effects of SARA participation and, more broadly, provide insight into the impact of shifting regulatory burden.


James Dean Ward is a researcher at Ithaka S+R with the Educational Transformation team. His work focuses on federal and state higher education policy. James earned a BA in economics and history from Cornell University and a Ph.D. 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. Prior to joining Ithaka S+R, he conducted research with the Pullias Center for Higher Education at the University of Southern California and the National Association of College and University Business Officers.

Ben Weintraut is an analyst fellow at Ithaka S+R with the Educational Transformation team. 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.

Martin Kurzweil is director of the Educational Transformation Program at Ithaka S+R, which studies and supports the implementation of practices, policies, and innovations that improve student postsecondary access and success. He was previously an academic fellow at Columbia Law School, where his research and teaching focused on administrative law, federalism, and organizational governance in the context of K-12 and higher education. Prior to joining Columbia, he was senior executive director for Research, Accountability, and Data at the New York City Department of Education. A graduate of Harvard College and Harvard Law School, Martin clerked for Judge Pierre Leval of the U.S. Court of Appeals for the Second Circuit and has also worked as a litigator at Wachtell, Lipton, Rosen, and Katz, and as a researcher at The Andrew W. Mellon Foundation. Martin has published widely on various topics in education, in outlets ranging from the Huffington Post to the California Law Review. He is the co-author of Equity and Excellence in American Higher Education, which received the 2006 American Educational Research Association Outstanding Book Award.

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.


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

Jason Lee, senior policy analyst