1. Purpose
The purpose of this Student Physical Location Policy is to establish clear, consistent institutional procedures for identifying, recording, maintaining, and updating the physical location of prospective and enrolled students, in compliance with:
- Federal Title IV disclosure regulations (34 CFR 668.43 and 668.14)
- NC‑SARA Policy Manual requirements regarding student location tracking and licensure disclosures
- NYSED expectations for SARA‑participating institutions
This policy supports accurate licensure disclosures, consumer protection, SARA reporting, and regulatory compliance.
2. Scope
This policy applies to:
- All prospective students at the point of application
- All enrolled undergraduate, graduate, and non‑degree students
3. Determination of Student Location
- In general, student location is defined as the location where a student is physically present during the educational activity.
- At matriculation, student location will be the campus address if the student is living on campus or the local mailing address otherwise.
- Students must update their physical location at the time of registration for each term, if it has changed from the above.
- For distance education students, the location is defined by the state orientation where the student is physically present while completing coursework.
- For out of state learning placements, the physical location of the experiential site also constitutes the student’s location. Programs with such placements gather information on placement locations and provide it to the Director of Institutional Research and Effectiveness annually.
4. Student Responsibilities
- Students must provide accurate address information and notify the Registrar of any change in their location within 10–14 days.
- A location change may affect:
- Professional licensure eligibility
- Ability to participate in experiential placements
- Cost of attendance or aid eligibility
5. Institutional Responsibilities
- The Registrar maintains official student location data in Banner.
- The Registrar and Director of Institutional Research and Effectiveness review location changes to determine whether:
- Additional professional licensure disclosures are required
- Program adjustments are necessary
- SARA reporting is impacted
- In compliance with federal regulations, the institution must issue direct, individualized disclosures when:
- A program does not meet the educational requirements for the student's state
- The institution has not determined whether requirements are met
- The Registrar or academic program staff are notified that a student has changed location to another state
- Direct disclosures must be sent within 14 days, where applicable, by a representative of theAcademic Affairs office.
- The Director of Institutional Research and Effectiveness collects and reports:
- Out‑of‑state learning placements
- Exclusively distance‑education enrollments
6. Responsibilities of Academic Programs
Academic departments offering licensure‑related programs must:
- Maintain updated state‑by‑state licensure determinations
- Annually review with the Director of Institutional Research and Effectiveness to ensure accuracy
- Provide updated direct disclosures when program requirements change
7. Compliance and Enforcement
Failure to follow this policy may result in:
- Inaccurate SARA reporting
- Improper federal disclosures
- Risk to institutional Title IV eligibility
- Risk to the University’s membership in NC-SARA
- Penalties levied against the University by the Department of Education
Questions should be directed to the Director of Institutional Research and Effectiveness.
8. Policy Review Cycle
This policy will be reviewed every three years or sooner if required by changes in federal regulations, SARA policy, or NYSED requirements. Review will be coordinated by the Director of Institutional Research and Effectiveness.