NC-SARA Institutional Application Requirement 14: Institutions must maintain well-documented policies and practices for addressing catastrophic events and provide them upon request to the State Portal Entity.

Council on Occupational Education (COE) Standard VII(A)(3): The institution must maintain plans for protecting student records and continuing operations in the event of natural or man-made disasters.

Texas Higher Education Coordinating Board (THECB) – Private Postsecondary Institutions: Institutions are required to demonstrate continuity planning to ensure students receive the services for which they have paid.

This policy establishes Graduate America’s framework for preparedness, response, recovery, and communication in the event of a catastrophic or disaster-level incident. It applies to all campuses, instructional sites, and distance-education operations governed by Graduate America, including approved affiliates and apprenticeship sites.

For institutional purposes, a “catastrophic event” includes—but is not limited to—natural disasters (hurricanes, tornadoes, floods, fires, or pandemics), infrastructure failures (power or internet outages), cyberattacks, acts of violence, or other crises that significantly disrupt normal operations or threaten safety, data, or instructional continuity.

President (Malcolm Allen): Authorizes activation of this policy, oversees institutional response, and communicates with regulatory bodies (THECB, SARA, COE, VA, TWC).

Campus Director(s): Implement site-specific response and student communication.

Director of Education: Coordinates instructional continuity through LMS and remote delivery.

Director of IT: Executes digital data recovery and server restoration.

Registrar: Protects academic records, ensures transcript availability, and supervises secure student data backups.

In the event of an emergency:

Immediate Safety: Evacuate or shelter in place per campus safety plan and notify local emergency services.

Notification: All staff and students will be contacted via text, email, and posted alerts through the institution’s LMS (Canvas).

Instructional Continuity: Within 72 hours, instruction will transition to online delivery to minimize disruption. Faculty will use pre-approved virtual teaching tools and maintain attendance and grading integrity.

Administrative Operations: Payroll, financial aid, and student services will continue remotely through secure cloud systems.

Data & Record Security: All academic, financial, and HR records are encrypted and backed up nightly to secure cloud servers located outside the primary data region.

Backup Systems: Cloud-based redundancy for LMS, SIS, and accounting platforms.

Testing and Verification: IT conducts quarterly data-restoration tests to ensure backup integrity.

Facility Recovery: Each campus maintains insurance for property restoration and operational resumption within 30 days where feasible.

Critical Vendor Recovery: Contracts include continuity clauses requiring vendors to maintain operations during disasters.

Graduate America ensures that impacted students receive either:

The instructional services for which they have paid (through resumption, online delivery, or teach-out), or

Reasonable financial compensation for those not received.

Consumer protection measures include:

Active surety bond coverage with TWC.

Teach-out agreements with partner institutions as approved by COE.

Transfer and records assistance for displaced students.

Graduate America will communicate promptly and transparently during and after any catastrophic event:

Students and staff receive alerts via email, SMS, and LMS notices.

Updates will be posted on www.GA.edu/ and all official social media channels.

The President or designee will notify the Texas SARA State Portal Entity and THECB of any event materially affecting operations or student access within 10 business days.

All permanent student records, including transcripts and financial aid data, are securely stored in FERPA-compliant cloud databases with multi-factor access control. In the event of permanent closure, student records will be transferred to the Texas Higher Education Coordinating Board (THECB) per §132.101 of the Texas Education Code.

This policy is reviewed annually during the institutional effectiveness cycle and after any activation event. The Disaster Recovery Team performs simulation drills each semester to test system reliability and communication effectiveness.

NC-SARA Policy Manual (2024): Section II, Institutional Eligibility, Requirement 14

COE Handbook of Accreditation: Standard VII(A)(3), Institutional Planning and Evaluation

Texas Education Code §132.101 – Record Protection for Career Schools and Colleges

Malcolm Allen, President
Graduate America
Date: _________________
Contact: info@GA.edu | 972-530-1103
Website: www.GA.edu