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This study systematically investigated levels of state adherence to the federal requirements set forth pursuant to the Sex Offender Registration and Notification Act (SORNA), passed in 2006. Along with these requirements, SORNA provided for establishing the Office of Sex Offender Sentencing, Apprehension, Registration, and Tracking (SMART), and charged this office with certifying state-level implementation of these guidelines. Data for this analysis were drawn from a series of detailed “compliance letters” issued by the SMART Office to designated state officials, pursuant to SMART review of each state’s adherence to the 14 general SORNA guidelines. As of February, 2017, 18 states have been designated as substantially implementing SORNA. The current presentation focuses on exploring the multi-faceted dynamic nature of state-level implementation of SORNA requirements, and underscores the need to recognize SORNA implementation as more than a dichotomous designation. Results indicate SORNA standards may be implemented by states in varying ways, and that there is no single pathway to SORNA implementation. Policy implications will be discussed.