Policy: 

In accordance with federal, state, and the National Council for State Authorization Reciprocity Agreements (NC-SARA) requirements, Clarkson 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 indicate whether the Clarkson College program meets licensure requirements in the state of the student’s location.  

Definitions (referenced by NC-SARA Policy Manual) 

• National Council for State Authorization Reciprocity Agreements (NC-SARA) and State Authorization Reciprocity Agreement (SARA):  NC-SARA is a private, nonprofit organization that helps expand students’ access to postsecondary educational opportunities and ensure more efficient, consistent, and effective regulation of distance education programs through SARA. SARA provides state authorization portability for higher education institutions in the United States. NC-SARA serves as a national leader in enhancing quality and consumer protections in interstate postsecondary distance education. 

• Student Location: Student location is the state where a student resides and is based on the permanent home address maintained in Clarkson College’s student information system (SIS) at the time of initial enrollment. 

• Professional Licensure or Licensure: Defines a process of state or other governmental entities that establishes standards of practice and gives legal permission to practice a profession by providing licenses or certifications to individuals who meet those standards. 

• Out-of-State Learning Placement: Defines experiential learning placements such as, but not limited to, clinical rotations, internships or student teaching offered by SARA-participating institutions in locations outside their home state. 

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

• Distance Education: Defines instruction offered by any means where the student and faculty member are in separate physical locations. It includes, but is not limited to, online, interactive video and correspondence courses or programs. 

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: 

a. For a specific license and  

b. Is required for employment in an occupation or 2.

2. Marketed or advertised for educational programs.  

Clarkson College must review the state board requirements for each licensed profession in every state annually to determine whether the institution’s educational programs fall within the state’s regulatory oversight for professional licensure. Clarkson 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 Clarkson College’s 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 maintained within Clarkson College’s SIS. 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 Clarkson College’s SIS 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 MyCC. Once a student enters a new U.S. State or Territory, Clarkson College will consider that date of entry as the effective date of a student’s revised location for 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 Clarkson 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. 

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

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 leads to professional licensure:   

1. Does meet the state educational requirements, or 
2. The institution does not meet the state educational requirements for the state in which the student is located.  

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

1. A student completes the Change of Address process and relocates to a state where the program does not meet the educational requirements for licensure or certification. 2
2. The institution decides 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 the 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.  

Procedure: 

Responsibilities and Determination of State Licensing and Certification Requirements  

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

Any changes to a U.S. State or territory’s board or professional licensure requirements or Clarkson College’s ability to meet these requirements must be documented and updated on Clarkson College’s State Authorization & Professional Licensure page on the website. The Program Directors/representatives will inform the Clinical Compliance Office and the Director of Enrollment and Advising of any changes. The Clinical Compliance Office maintains all State Authorization information and requests updates to the website from the Division of Communications and Development.  

Students currently enrolled in and/or considering enrollment in a Clarkson College program are responsible and should be mindful of the implications when considering relocation to a state where the institution is not authorized. While Clarkson College endeavors to secure approval in all states where its students reside, relocating to a non-authorized state may lead to adverse outcomes such as loss of eligibility for specific financial aid options or the inability to fulfill academic program requirements.  

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 or not met) 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 required to read and acknowledge that 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 Clarkson College or signing an enrollment agreement).  

The Enrollment and Advising Department will determine the appropriate disclosure to be sent to the student based on the 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 the student initiates a change of student location through the Change of Address process. When a student initiates the Change of Address process through the MyCC portal, the 14-day timeframe for disclosure begins.  

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) 

• 34 CFR § 668.14(b)(32) 

• NC-SARA Manual 23.1 December 8, 2023US Department of Education Program Participation Agreement