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SUNY ESF
Student Location Policy

Policy Statement

The State University of New York College of Environmental Science and Forestry (SUNY ESF, "the College") determines student location for purposes of state authorization, participation in the State Authorization Reciprocity Agreement (NC-SARA), and the administration of distance education and related out-of-state educational activities.

This policy exists to comply with federal regulations on state authorization (34 CFR 600.9) and professional licensure disclosures (34 CFR 668.43 and 668.14(b)(32)).

This policy applies only to student location determinations made for state authorization, NC-SARA compliance, and professional licensure disclosure purposes. It does not apply to any other determination of student  location, including but not limited to residency for tuition purposes, IPEDS reporting, or any other institutional purpose.

Rationale

Federal regulations require institutions offering distance education to determine, and in some cases disclose, the state in which a student is located — both to confirm the institution holds appropriate authorization to offer instruction in that state and to disclose whether a program leading to professional licensure or certification meets that state's licensure requirements.

Under 34 CFR 668.43(c)(3)(ii), the College’s determination of a student’s location becomes operative at the time of the student’s initial enrollment in an educational program, using the address most recently on file for the student, ordinarily the permanent address reported at the time of application. Location is reassessed if the student later declares, or is admitted into, a program leading to eligibility for professional licensure or certification, or upon formal receipt of information from the student that their location has changed.

Applicability

This policy applies to all matriculated and enrolled SUNY ESF students — including students in on-campus, online, and hybrid programs, visiting and exchange students, and students participating in out-of-state internships, field experiences, or other supervised educational activities that may occur outside New York State — for whom state authorization, NC-SARA compliance, or professional licensure disclosure requirements apply.

Applicants are not students of the College and are not otherwise governed by this policy. However, because a student’s initial location is established using information collected at the time of application (see Determining Initial Location, below), this policy describes how that information is collected and used so that a location determination is already in place when an applicant matriculates and becomes a student.

Policy Elaboration

Determining Initial Location

For purposes of state authorization and disclosure of information about licensed programs, the College’s determination of a student’s location takes effect at the student’s initial enrollment in an educational program, using the permanent address the applicant reported on the admission application, as that will likely be the only address on file. This determination remains in effect upon matriculation, subject to the ongoing determination rules below.

Determining Location Following Registration

Upon matriculation and registration in courses, the College determines a student's location based on the address information maintained in the College's student information system, applied as follows:

  • A student living in on-campus housing is determined to be located in New York.
  • For all other students, location is determined based on the student's reported local address; where no local address is on file, the student's permanent address is used.

Ongoing Determination

A student is determined to be located in New York if any of the following apply:

  • The student's permanent residence is in New York State.
  • The student's local address is in New York State.
  • The student resides in on-campus housing.

Professional Licensure Attestation

Under 34 CFR 668.14(b)(32), a program offered through distance education must meet the licensure or certification requirements of the state in which the student is located. This requirement does not apply to a student attending a program face-to-face; that student is instead governed by the licensure requirements of the state in which the College is located.

Where the College has determined that a distance-education or correspondence program does not meet the requirements of the state in which the student is located — or has not yet made a determination for that state — 34 CFR 668.14(b)(32)(ii) permits the College to still enroll the student if the student provides a written attestation confirming their intent to seek licensure or certification in one specific state in which the College has determined the program does meet requirements.

Because the attestation exists to permit enrollment that would not otherwise be allowed, it must be obtained before the student enrolls in the program. The attestation will be built into application and change of major processes. 

Definitions

Student Location — A student's physical presence in a state, as determined by SUNY ESF based on institutional records, solely for the purposes of compliance with federal state authorization and professional licensure disclosure regulations.

Applicant — An individual who has submitted an application for admission to SUNY ESF but has not yet matriculated. Applicants are not students and are covered by this policy only with respect to the collection of initial location information under Determining Initial Location.

Matriculated Student — A student who has been formally admitted to, and is pursuing, a degree, certificate, or other credit-bearing program of study at SUNY ESF.

Enrolled Student — Any student registered for one or more courses at SUNY ESF in a given term, whether matriculated in an ESF program, visiting, or otherwise non-degree-seeking. All matriculated students are enrolled students during terms in which they are registered, but not all enrolled students are matriculated.

Visiting Student — A student who is registered for one or more courses at SUNY ESF for a limited period while matriculated in a degree program at another institution, including students participating in a formal exchange agreement.

Permanent Residence — The address provided by the student at the time of application and maintained in the College's student information system, as updated by the student when changes occur.

Local Address — A temporary or current address, reported by the student and maintained in the College's student information system, that differs from the student's permanent residence.

On-Campus Housing — Residential facilities designated by the College as on-campus student housing, regardless of which entity holds legal ownership of the facility or is contracted to manage its day-to-day operations.

Procedures

Students are responsible for maintaining accurate and current address information in MyESF. The College may rely on the address on file when making determinations under this policy.

A student's determined location remains in effect until a change of address is officially submitted by the student and recorded by the College in MyESF. The effective date of a revised location determination is the date the change is recorded in College systems. The College reserves the right to reassess a student's location if institutional records indicate a change in physical presence.