Physical Presence Triggers

While there is no single standard for what it means to "operate" or engage in "educational activities" within a state, many states (not all) determine the need for authorization based on physical presence. All states define physical presence differently, requiring the University of Utah to evaluate our activities on a program-by-program basis for each state in which we operate.

Physical presence can be triggered by any residential, campus-based program (even if there is no online delivery of classes). Common physical presence "triggers" that would require the University to seek authorization in another state include:

  • Offering distance education courses that include field experiences (internships, externships, clinical practicum, medical rotations, and other times of field placements). Please see the Out-of-State Field Placements and Professional Licensure pages for additional requirements that may affect your program's placement decisions.

  • Advertising in local media or specifically targeting residents of a state in marketing campaigns.

  • Employing faculty, staff, or other university employees who are reside outside of Utah.

  • Housing administrative or instructional spaces outside of Utah.

  • Requiring students to take proctored exams.

  • Recruiting students at job fairs, conferences, and other events.

If your program or department engages in any out-of-state educational activities (such as those listed above), please contact us to determine if any authorizations are required before you begin.

Additional Information: Physical Presence Triggers

Regulations and laws regarding state authorization requirements change frequently, and sometimes without notice. These resources may serve as a general guide regarding what activities might trigger authorization, but departments should contact the State Authorization Coordinator directly to determine if any approvals are necessary before engaging in educational activities outside of Utah.



Contact State Authorization

Amanda Jean Babcock

(801) 585-5819

Lyndi Duff
(801) 587-7843