Changing Regulations: Game Planning for Professional Licensure Program Notifications for All Modalities

Concurrent Session 3
Streamed Session Leadership

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Session Materials

Brief Abstract

Federal regulations require notifications for programs leading to professional licensure, regardless of modality, to ensure students are making informed decisions about institutions.  Does your institution have a plan to track students, research requirements, and provide required notifications?  Join us to discuss the development of an institution compliance game plan.


Russ Poulin leads the WICHE Cooperative for Educational Technologies, which advocates for effective practices and policies for digital learning in higher education. WCET’s members represent institutions, state agencies, corporations, and non-profit organizations from all fifty states. In paying attention to federal, state, and institution policies, he twice represented the distance education and competency-based education communities in federal negotiated rulemaking processes. The Presidents’ Forum, Excelsior College, the National University Technology Network, and the Online Learning Consortium have all recognized Russ for his contributions. He is also partial to movies, cats, and his wife, Laurie. Contact: or @RussPoulin.

Extended Abstract

Recently, the United States Department of Education released Federal regulations requiring that postsecondary institutions that disburse Federal financial aid must provide general and direct notifications regarding their programs that lead to professional licensure or certification regardless of the modality of the program.   The reasoning for the notifications is to assist students to make informed decisions about the choice of a postsecondary institution that will provide students with the skills and education to be licensed or certified in their desired profession in a particular state. An institution is tasked with determining whether or not the institution’s program curriculum meets state educational requirements for all of the institution’s face to face and distance education programs that lead to professional licensure or certification. 

A similar professional licensure notification requirement is placed upon the institution in order to participate in reciprocity for state institutional approval, as managed by NC-SARA and the four regional education compacts. 

Institutions should be aware that program approval is in addition to institutional approval. State institutional approval provides that the institution may, generally speaking, legally provide activities in a state.  Separately, state licensing boards for some programs leading to professional licensure or certification require program approval in the state where the student is located while participating in a program leading to licensure or certification.   Institutions that obtain institutional approval by participation in reciprocity through SARA may have the mistaken belief that reciprocity extends to program approval by state licensing boards.  Failure to obtain required state program approval could prevent a student from completing licensure or certification requirements in a state.

Research of the state requirements to obtain program approval, if required, and subsequent notifications of the determination of whether the institution’s curriculum meets state educational requirements is an important undertaking to serve students participating in the institution’s licensing programs.  Transparency by the institution is critical for the student with aspirations of a career in a profession. One should consider that in this increasingly mobile society that students will desire flexibility to choose the best employment opportunity in their profession from a variety of states.

To complete program approvals and required notifications, the institution must develop a comprehensive institutional game plan that includes a variety of key stakeholders at the institution.  Stakeholders may include:  the Provost, General Counsel, Registrar, Financial Aid Office, Institutional Research, Accreditation Team, Academic Departments, and Compliance Staff Member(s).

Stakeholders may wish to develop a plan and identify responsibilities that include the following steps:

  • Identify programs leading to professional licensure or certificate.
  • Track student location.
  • Complete professional licensing research.
  • Obtain program approval, if required.
  • Create an institution general notification process
  • Maintain the research and notification process.

This session will begin with an interactive format to ascertain the level of knowledge among the session participants of state authorization and professional licensure notification requirements.  We will quickly touch on the development and philosophy of the regulations.  Because a comprehensive institution game plan is of utmost importance, we will spend the bulk of the time sharing a multi-step approach for which institutions may follow and modify to their needs to create a compliance strategy for their institution.  Challenges will be identified, and resources will be shared.  We will conclude with opportunity for questions.