1. Overview

   It is important to know where students are living for emergency purposes. 

   Additionally, when offering educational opportunities outside of Ohio, whether by distance education or courses such as internships, clinicals, practica, and student teaching, the university must comply with applicable state and federal regulations. Current regulations require an institution to be authorized by a state where the institution is not physically located when delivering education to students who reside within that state. 

   Universities offering programs leading to, or that could be assumed to lead to, professional licensure are required to notify students as to the applicability of the education being delivered to the various state professional licensure education requirements. Compliance with these state, federal, and other regulations relating to state authorization and licensure is critical to allowing the university to fulfill its mission as a public research university. 

2. Applicability 

   This policy applies to all students enrolled in credit-bearing coursework at Ohio University, regardless of campus, modality, or level. 

3. Definitions 

   1. Distance Education is education that uses one or more technologies (e.g., internet, communications devices, audio or video conferencing) to deliver instruction to students who are separated from their instructor and to support regular and substantive interaction between students and the instructor, either synchronously or asynchronously (per Reference 2.a. 34 CFR 600.2).
      1. Distance Education Program is a certificate or degree program in which 50% or more of the courses may be taken as distance education courses. 
      2. Distance Education Course is a course in which at least 75% of the instruction and interaction occurs using one or more of the technologies listed in the definition of distance education, with the faculty and students physically separated from each other. 
   2. Location is defined as the state/territory where a student is located while receiving instruction. The student's location may differ from the student's state of legal "residence" that is the place where they are registered to vote or hold a driver's license (per Reference 2.a. 34 CFR 668.43). Additionally, a student's location for the purposes of receiving instruction may be different from their address. 
   3. Out-of-state learning refers to distance education courses or programs and field experiences such as, but not limited to, clinical rotations, internships or student teaching outside of the state of Ohio. Courses such as independent studies, test prep, dissertation or thesis credits, or correspondence courses do not fall under these regulations as there is no regular or substantive interaction with the university or other designee (per Reference 2.b.).

4. Address Types 

   1. Home Address

      Students are required to provide a permanent address on their applications for admission. Students are expected to keep this address current and may update this address via self-service in the student information system. 

   2. Mail Address 

      Students may provide a mailing address on their applications for admission. Students are expected to keep this address current and may update this address via self-service in the student information system. 

   3. Current Living Address 

      All students who are not living in university housing and who have not reported a SEVIS US address are required to confirm or update the address where they are living each semester prior to participating in class. Students will be prompted to update or confirm this address each semester in advance of their first day of class. In addition, students may update this address anytime via self-service in the student information system. Students are expected to update this address if they move during the semester. 

   4. Diploma Address 

      Students are required to provide an address to which their diploma or certificate is mailed when they apply for graduation. This address may be updated only by staff in the office of the university registrar by request of the student after their application for graduation is complete. 

   5. SEVIS Foreign Address 

      All international students in F-1 and J-1 status must report their foreign address within ten days of moving. Students are required to update this address via self-service in the student information system to remain in compliance with immigration regulations. 

   6. SEVIS US Address 

      All international students in F-1 and J-1 status must report their United States address within ten days of moving. Students are required to update this address via self-service in the student information system to remain in compliance with immigration regulations. 

   7. Residence Hall Address 

      All students living in university housing have a residence hall address. This address is updated automatically and may not be be updated by the student. 

5. Determination of Student Location

   OHIO determines the location of a student for the purposes of providing accurate professional licensure disclosures and reporting. 

   OHIO will determine a student's location (state):

   1. After a student's initial application to an educational program that leads to professional licensure or when a student changes their major to a new licensure program; 
   2. at the time of initial enrollment in the licensure program; 
   3. each semester a student is registered for classes while enrolled in a licensure program; and
   4. when a student who is enrolled in a licensure program officially changes any of the addresses used in determining their location. 

   Procedure 

   When determining a student’s location, if the student is registered for or enrolled in only in-person courses (including OULN courses where students are physically present in a classroom), they will be considered located in Ohio for the purposes of receiving instruction.

   If a student is not yet registered for any courses or is registered for or enrolled in one or more distance education courses (not including OULN courses where students are physically present in a classroom), the student's location will be determined using their address information and the following hierarchy:

   1. Residence Hall Address or indication of intent to reside in university housing, such as but not limited to a housing deposit or housing contract:
      
      The student will be considered located in Ohio. 

   2. SEVIS US Address:

      The student will be considered located in the state identified in their SEVIS US Address.

   3. Current Living Address:

      The student will be considered located in the state identified in their Current Living Address.

   4. No active Current Living Address and registered for or enrolled in one or more in-person courses (including OULN courses where students are physically present in a classroom):

      The student will be considered located in Ohio. 

   5. Home Address and student is not yet registered for courses or is registered for or enrolled in only distance education courses (not including OULN courses where students are physically present in a classroom):

      The student will be considered located in the state identified in their Home Address.

6. Application and use of data/information 

   Address information will be used as indicated by university policy, 12.020 Student Records. This paragraph includes some specific examples of how the current living address may be used. 

   The student's current living address may be used for emergency purposes such as needing to locate a student or identify all students living in a certain vicinity. 

   A portion of the collected student address data (i.e. location) is reported annually to the national council for state authorization reciprocity agreements (NC-SARA) as part of the University's participation agreement. It is important to note that no individually identifiable student data is reported in this annual update. 

   For purposes of compliance with applicable federal regulations such as professional licensure regulations and state authorization agreements, student location and/or information from the current living address may be used for notifications and reporting. 

Reviewers 

Proposed revisions of this policy should be reviewed by: 

1. Vice President for Enrollment Management 

2. Vice President for Communications and Marketing 

3. Assistant Vice President and Executive Director of Student Financial Aid and Scholarships 

4. Assistant Vice President for Enrollment Management and Executive Director of Undergraduate Admissions

5. Academic Deans 

6. Vice Provost for OHIO online 

7. Associate Provost for Institutional Effectiveness and Analytics 

8. Director of International Student and Scholar Services 

9. Chief Privacy Officer 

10. Director of University Compliance 

11. Dean of Students 

12. Student Senate 

13. Graduate Student Senate 

14. Assistant Vice President for Student Information Strategy and University Registrar 

Forms, References, and History

1. References

   The following items are relevant to this policy: 

   1. Federal/Department of Education Regulations  (effective 7/1/2020) see 34 CFR 600.2, 600.9, 668.43

   2. National Council for State Authorization Reciprocity Agreement  Version 21.1, May 28, 2021

   3. Higher Learning Commission Assumed Practices A.7.b and A.10 

   4. NC-SARA Guidelines 5.2 Programs Leading to Professional Licensure (updated 6/12/20) and 5.12 Student Mobility

   5. WCET State Authorization Network Compliance management for out-of-state activities 

   6. Policy 12.020 "Student Records" 

2. History

   Draft versions of this policy that were circulated for review, their cover memos, their forms, and Reviewers' comments on them are available on the password-protected Review site.

   Prior versions of this policy were approved on:

   1. August 16, 2024 (ESPC approved for interim us in accordance with policy 01.001) 
   2. May 31, 2023