Student Location & Disclosures for Professional Licensure or Certification Disclosure (Policy OG-33)

In accordance with federal, state, and the National Council for State Authorization Reciprocity Agreements (NC-SARA) requirements, the College must have a policy and procedure required for professional licensure disclosures, both general and individual. These disclosures or notifications are specific to students in educational programs leading to professional licensure or certification and whether the College program meets licensure requirements in the state of the student’s location.

The professional licensure disclosures are required for Title IV funding, but the educational programs that may lead to licensure and are impacted are based upon the various state professional board requirements. 34 CFR §668.43 Institutional Requirements, under (a)(5)(v) provides two elements of a program likely to lead to professional licensure where it refers to an educational program “designed to meet educational requirements for a specific professional license that is required for employment in an occupation or is advertised as meeting such requirements…”. Thus, an institution must provide the required disclosures regarding whether completion of the educational program would be sufficient to meet the respective state licensure requirements for the occupation, if the program is either:

  1. Designed to meet the educational requirements.
    1. For a specific license and
    2. Is required for employment in an occupation, or
  2. Marketed for advertised to meet educational requirements.

Clarkson College must review the state board requirements for each licensed profession in every state to determine whether the institution’s educational programs fall within the state’s regulatory oversight for professional licensure. The College is required to know what state requirements exist for an educational program to be offered to a student in a particular state, and the required approval that constitutes what is needed for the program to be authorized by that state. Professional licensing and certification requirements include:

  1. The requirements for an individual to be licensed in that state, and
  2. If the institution’s educational program curriculum satisfies the state professional board’s requirements so that a graduate of the institution is eligible to be licensed in that state (which may require state board approval of the program curriculum/content).

This information will serve as the guide for general/public and individual student disclosures.

The disclosures must be provided at the time of initial enrollment (prior to the student making a financial contribution to the college or signing an enrollment agreement) and when there is a change of student location as indicated by the college change of address process. For purposes of this policy, the student location is the state where the student resides and is based on their permanent home address entered into the college’s student information system.  For a prospective student, this is the state of the prospective student’s residence at the time the student applies for admission and is entered into the College Customer Relation Management (CRM) system. For any student whose residence does not include a U.S. state or territory (such as an international student), their place of residence will be considered the state of Nebraska. The student location designation will remain in effect unless and until a student changes the U.S. state or territory listed as the student’s permanent address using the student information system or completing the Change of Address Form on the College website. Once a student enters a new U.S. state or territory, the college will consider that date of entry as the effective date of a student’s revised location for the purposes of this policy.

NOTE: Licensing and authorization requirements can vary by state; therefore, any relocation by applicants and current students can impact their ability to continue course(s), meet the eligibility requirements of that state, and/or receive financial aid funding. Any student considering relocation should review the College State Authorization and Professional Licensure webpage and may contact their program director for more information regarding authorization and licensure eligibility requirements.

General Disclosures

For the general disclosure requirement, permitted under 34 CRF §668.43 (a)(5)(v)(A) through (C), institutions are required to disclose (by educational program with professional licensure or certification) a list of all states for which the institution:

  1. Has determined that its curriculum meets the state educational requirements for licensure or certification.
  2. Has determined that its curriculum does not meet the state educational requirements for licensure or certification; and
  3. Has not made a determination that its curriculum meets the state educational requirements for licensure or certification.

A listing of educational programs with professional licensure or certification by state will be included on the College State Authorization website.

Individual Disclosures

In addition to the general disclosures detailed above, under 34 CRF §668.43 (c) which requires an institution to provide a direct disclosure to enrolled and prospective students in writing if the program potentially leading to professional licensure either:

  1. Does not meet the state educational requirements (#2 general disclosures above), or
  2. The institution has not made a determination for the state in which the student is located (#3 general disclosures above).

For currently enrolled students, the College must provide a written individualized disclosure within 14 calendar days to a student if:

  1. A student completes the change of address process and the student relocates to a state where the program does not meet the educational requirements for licensure, or the institution has not made a determination that its curriculum meets the state educational requirements for licensure or certification.
  2. The institution makes a determination that the program’s curriculum does not meet state educational requirements for the state in which an enrolled student is located, or
  3. The institution later determines that the program does not meet the educational requirement for licensure in a state where the student is located.

This policy applies to students in all modalities (on campus or online) and all programs leading to professional licensure or certification.

Definitions

National Council for State Authorization Reciprocity Agreements (NC-SARA, known as SARA): SARA is an agreement among member states, districts and territories that establishes comparable national standards for interstate offering of postsecondary distance education. When states join SARA, they agree to follow uniform processes for approving their eligible institutions' participation. They also agree to deal with other states' SARA institutions in a common way when those institutions carry out activities in SARA states other than their own.

Student Location: Student location is the state where a student resides and is based on the permanent home address entered into the college’s student information system. 

Professional licensure/certification program: An educational program that can lead to professional licensure or certification to ensure a professional meets industry requirement in terms of knowledge, experience, and currency.

Procedure:

Responsibilities and Determination of State Licensing and Certification Requirements.

The program director/representative who oversees educational programs which end in a professional licensure or certification are responsible for maintaining the state-by-state board or professional licensure requirements. The determination of met, not met, or has not been determined will be assigned to all educational programs resulting in professional licensure and certification according to each U.S. State or territory. At minimum, these requirements will be reviewed annually.

Any changes to a U.S. state or territory’s board or professional licensure requirements or the College ability to meet these requirements must be documented and updated on the College State Authorization & Professional Licensure page on the website. The program directors/representatives will inform the President’s Office representative and the director of Enrollment and Advising of any changes. The President’s Office representative is responsible for maintaining all state authorization information and updating the website.

Additionally, any changes to the state board or professional licensure requirements must be also be communicated to the director of Enrollment and Advising for possible disclosures to students.

Responsibilities of Professional Licensure/Certification Disclosures

General Disclosure

General disclosure requirements are met by updating and maintaining the State Authorization & Professional Licensure page on the website. The website must include documentation of compliance (met, not met, or has not made a determination) for each educational program that includes U.S. state or territory’s board or professional licensure requirement.

As part of the application process, students are prompted to read and acknowledge they have read the appropriate State Authorization & Professional Licensure information.

Individual Disclosure for Prospective Students

Professional licensure and certification disclosures for prospective students will take place during the enrollment confirmation process (prior to the student making a financial contribution to the college or signing an enrollment agreement).

The Enrollment and Advising office will determine the appropriate disclosure to be sent to the student based on state of residence, educational program, and compliance with U.S. state or territory board or professional licensure requirements. The disclosure will be sent to the student via email during the confirmation process of enrollment into the educational programs.

Individual Disclosure for Currently Enrolled Students

Professional licensure and certification disclosure for currently enrolled students will only take place if a change of student location is initiated by the student through the change of address process.

When a student submits a change of address form through the student information system or through the change of address form located on the Clarkson College website, the 14-day timeframe for disclosure begins. The Registrar’s office will notify the Enrollment and Advising office and the program director/representative of a change to a student’s location immediately after the new address is entered into the student information system. Once the Enrollment and Advising office is notified of the student’s change of location and it has been determined that the student’s location requires a disclosure notification, the appropriate disclosure will be sent via the student’s Clarkson College email.

Individual disclosures for currently enrolled students are only required if a student relocates to a U.S. state or territory in which the educational program does not or has not yet determined compliance with the U.S. state or territory board or professional licensure requirements.

REFERENCES

  • 34 CFR § 668.43(c)(1)
  • 34 CFR § 668.43(c)(2)
  • 34 CFR § 668.43(a)(5)(v)
  • 34 CFR § 600.9(c)(2)
  • NC-SARA Manual 20.1_Final_2.6.20

Registrar’s Office-Change of Address Form: https://www.clarksoncollege.edu/default/assets/File/AddressChangeRequestForm.pdf