What is the Rule of 10 for Out-of-State Field Experiences?

Whether you are new to state authorization, or you’re already familiar with laws that impact students being educated outside Ohio, you may have heard of the “Rule of 10.”

What is the Rule of 10, and how can you help The Ohio State University maintain compliance?

Reciprocity agreements

Federal, state and professional licensing board regulations impact online and on-ground education offered across state lines. Compliance with these regulations ensures that an Ohio State degree will be recognized and that a student will be eligible to sit for licensure in other states. Ohio State’s participation in the State Authorization Reciprocity Agreement (SARA) streamlines processes for Ohio State to offer many educational activities in 49 SARA member states without seeking individual authorization in each state.

The Rule of 10

SARA participation allows Ohio State to place students in many out-of-state field experiences, such as clinicals and internships, in other SARA states. However, there are some limits on out-of-state placements under SARA. Colloquially called the Rule of 10, Section 5.11 d. 1. in the manual for the National Council for State Authorization Reciprocity Agreements (NC-SARA) sets 10 as the maximum number of students from an individual academic program that may be placed simultaneously at one clinical or practicum site in a SARA state. The placement of more than 10 students may require additional authorization.

The following hypothetical scenarios demonstrate application of the Rule of 10:

• Six Ohio State students in the Master of Science in Nursing program and seven Ohio State students in the Master of Respiratory Therapy program are completing clinical coursework at a hospital in Indiana. The Rule of 10 is not triggered because fewer than 10 students from each program are at the hospital. Additional authorization is not required.
• Seven Ohio State students in the Master of Science in Nursing program are completing clinical coursework at a hospital in Detroit, Michigan and eight Ohio State Master of Science in Nursing students are completing clinical at a hospital in Ann Arbor, Michigan. The Rule of 10 limit is not triggered because fewer than 10 students are present at each facility. Additional authorization is not required.
• Six Ohio State physical therapy students are completing clinical coursework at a Virginia hospital during autumn semester. Six more physical therapy students complete clinical coursework at the same hospital the following spring semester. The Rule of 10 limit is not triggered because fewer than 10 physical therapy students are completing clinical coursework at the hospital simultaneously. Additional authorization is not required.
• Fourteen Ohio State students in the Master of Science in Genetic Counseling program are completing clinical coursework at a hospital in Illinois during autumn semester. The Rule of 10 limit is triggered because the students are simultaneously completing a placement at a hospital in a SARA state. Additional authorization may be required from the Illinois Board of Higher Education.

NC-SARA implemented the Rule of 10 with the goal of ensuring that in-state students have access to ample placement opportunities in the state where they are located. The Rule of 10 is one of several limits to out-of-state activities covered by SARA. For example, out-of-state field experiences in a licensed field may also require approval from the state professional licensing board in the state where the placement is completed.

How you can help

To help maintain compliance with the NC-SARA Rule of 10, email the state authorization team prior to placing more than 10 students simultaneously at a facility in a SARA state. The Rule of 10 does not prohibit an institution from placing more than 10 students at a facility, but additional approval may be required. The state authorization team will research any authorization requirements, discuss compliance options prior to the start of the field experience, and submit any applications required to move forward with the placement.

Email the state authorization team with any questions about the Rule of 10 or other authorization requirements.