Professional Licensure Public Disclosures: Where are they?
Over the past 6 months, HELP has discovered trends as to how institutions are meeting the federal and NC-SARA professional licensure public disclosure requirements. Spoiler alert: for the most part, they aren’t!
New federal regulations (34 CFR 668.43(a)(5)(v) & 34 CFR 668.43(c)) added to the Higher Education Act (HEA), effective July 1, 2020, require institutions of higher education to:
Provide a general disclosure to prospective and enrolled students whether a program leading to professional licensure or certification meets educational requirements in each U.S. state and territory. The regulations apply to all types of instruction (e.g., in-person, online) and include specific wording.
Provide an individualized direct notification to:
Prospective students prior to their enrollment in the program if the curriculum does not meet the educational requirements in their state or territory or if the institution has not made a determination.
Enrolled students within 14 days of the institution's determination that the curriculum does not meet the educational requirements in their state or territory.
The National Council for State Authorization Reciprocity Agreements (NC-SARA) Board aligned their policy with the new HEA federal disclosure requirements and added the expectation that its members make reasonable efforts to determine whether their curricula meet state and territory educational requirements. See Sara Manual section 5.2 - Programs Leading to Professional Licensure - Version 20.2 revised June 15, 2020.
Changes for approval requirements to maintain GI Bill participation in Public Law 116-315, Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020, signed January 5, 2021. Section 1018: Requirements for educational institutions participating in the educational assistance programs of the Department of Veterans Affairs, effective June 15, 2021, and will apply to Institutions of Higher Learning and Non-College Degree institutions beginning August 1, 2021. These changes are related to the requirements of the Principles of Excellence with which many of you are already familiar. Section 1018(f)(1)(A)(ix) requires individualized disclosure of any conditions or additional requirements, including training, experience, or examinations, required to obtain the license. certification, or approval for which the course of education is designed to provide preparation (see Public Law 116-315).
Most institutions are not in full compliance
Colleges and Universities are aware of the federal regulations and NC-SARA policy requiring them to disclose how their programs (leading to a certificate or professional license) meet or do not meet licensure requirements in all U.S. states and territories. Yet to a large extent they are not meeting them.
Based on an informal audit of social work programs offered online and distance education that are approved or in candidacy by the Council on Social Work Education (CSWE):
A slight majority provided either no information or a statement was provided with links for students to check on requirements (BSW: n=19, 51%; MSW: n=15, 36%)
About a third stated they meet requirements for their home state and have not yet made a determination for any other state (BSW: n=11, 30%; MSW: n=13, 31%)
Twenty to thirty percent of programs were close to meeting Title IV disclosure requirements - providing a state by state listing with meets, does not meet, or no determination has been made (BSW: n=7, 19%; MSW: n=14, 33%)
Only two programs included listing for U.S. territories
Some examples of disclosure statements we found that do not meet the federal regulation:
Providing the federal regulation language only.
The...State University has not determined whether its programs meet other states’ educational or professional requirements for licensure and certification. Students enrolled in a...State University program who are planning to pursue licensure or certification in other states are responsible for determining whether they will meet their state’s requirements for licensure or certification. This disclosure is made pursuant to 34 CFR §668.43(a)(5)(v)(C).
All programs that lead to licensure and certification, should have a disclosure that alerts students to the requirements set forth by the licensing boards, in Ohio and, most importantly, out of state. These disclosures should be seen included in your webpages along with written correspondence. If you have any questions on what this disclosure should look like, please contact…. This is mandatory for all online programs and programs that offer field experiences out of state.
By the time you graduate, you will be prepared to sit for the Licensed Social Work Exam (LSW)*, which can qualify you for advanced practice roles and work in clinical settings.
* Licensure requirements vary by state. Students are responsible for understanding the requirements for social work licensure in their resident state. Applicants seeking licensure are encouraged to review all applicable eligibility requirements related to the respective occupational license per the Texas occupations code HB 1508.
Providing links to the state board or all state boards with a statement that it is the student’s responsibility to learn about the requirements for licensure in their home state.
If you are an online applicant who is applying to a graduate program leading to state licensure in a state other than Pennsylvania, please be aware of the various state professional licensure requirements. Use the links provided on the Graduate Application Page.
Obtaining a professional license is an important step in your professional development and the...College of Social Work would like to help you in this process. Every state in the United States has social work licensing, but the requirements vary. If you reside outside of Florida, please contact your state board of licensing and determine the specific requirements and either fax, mail, or scan the verification forms to us.
Providing information that the program meets requirements of the institution’s home state only.
Completion of the online MSW meets educational requirements to apply for a Master’s prepared Social Worker license in Indiana.
Stating the program fulfills many of the requirements in all states (no mention of U.S. territories):
The MSSA degree fulfills many of the requirements of social work licensure in all 50 states in the United States. To become licensed in any state, graduates must also complete the licensure exam and complete supervised hours (post-master’s). For an explanation of the various licensing requirements for social workers, please visit the Association of Social Work Boards (ASWB).
Stating that the program is accredited and therefore meets the requirements in all states.*
Social work regulatory boards require that social work degrees must be obtained from programs of social work that are accredited by the Council on Social Work Education (CSWE). Both the BSW and MSW at...University are accredited by CSWE and therefore meet the educational requirements to become a licensed social worker in other states. Some states may have requirements beyond the educational requirements in order to be licensed.
*While Council on Social Work Education (CSWE) accreditation is a requirement for social work licensure in all states, it is not the only educational requirement in all states. Twenty states require specific coursework or training requirements in addition to completion of a CSWE accredited degree to qualify for a license.
Providing information that the program meets, does not meet, or has not been determined to meet the requirements for all states but does not address U.S. territories.
The...Social Work program leads to a Master of Social Work degree. The Council on Social Work Education (CSWE) accredited program is designed to meet the eligibility requirements for the Association of Social Work Boards (ASWB) exam and not an initial license. Licensure requirements, including levels of licensure vary by state, and students should contact their state licensing board to determine the state specific requirements for licensure, including any additional requirements beyond the scope of the program.
The table below provides a state by state breakdown of comparable licenses, including a determination of eligibility for licensure. This information provided is designed as a baseline determination of whether the program meets individual state specific requirements. Licensure requirements, the type of license to apply for, and appropriate pathway to pursue are subject to change and may differ based on individual student backgrounds, including coursework taken outside the scope of the program. Students should do their own due diligence and determine the appropriate pathway and license type for themselves.
Colleges and universities are in a tough spot!
Even pre-pandemic, many lack people power. Institutions have to decide who is going to complete the work - legal research, curriculum comparison, disclosure language, and communicating with state licensure boards - required to understand and communicate.
Consider:
*Costs (monetary and opportunity)
*Time to complete
*Level of expertise
Review our Blog, Tips and Guidelines for Licensure Research” posted on February 22nd and look for our next Blog on Research Tips Part 2”