When Curriculum Comparisons are Necessary to Meet Professional Licensure Disclosures
In February 2020, we shared tips and guidelines for licensure research. Last November 2021, we posted information on best practices for student disclosures, beginning with determining student location and addressing both general and individual disclosures. In this post (June 2022), we discuss when it is necessary to compare your curriculum against state or territory requirements to determine whether your program (developed or advertised as leading to licensure) meets or does not meet educational requirements for professional licensure or certification across all U.S. states and territories.
Effective July 1, 2020, federal regulations (34 CFR 668.43(a)(5)(v) & 34 CFR 668.43(c) were added to the Higher Education Act, requiring higher education institutions to provide general and direct disclosures to prospective and enrolled students as to whether any program (leading to professional licensure or certification) meets educational requirements in each U.S. state and territory. The regulations apply to all modes of instruction: physical campus, online, or hybrid.
In general, there are two overall steps a higher education institution will need to take to effectively meet federal student disclosure requirements for its programs leading to professional licensure or certification:
First, to understand the requirements and
Second, to communicate them to prospective and current students.
To understand if a program meets educational requirements for licensure, some license types require a detailed comparison of courses to state- or territory-required educational content areas. Generally, educational requirements can be found and are clearly addressed in state statute and regulations. It is very helpful to also review licensure or certification application materials to understand how the Board is applying the statute and regulations in the application process. Even if all U.S. states and territories require the educational program to be accredited, a thorough review of statutes and regulations across all U.S. territories is needed to find unique coursework or training requirements.
Understanding curriculum is key to understanding if educational requirements for licensure are met. You will want to use your catalog to compare course titles and descriptions to the state or territory educational requirements. You may need to go to each course syllabus for a deeper level of comparison, looking for course competencies, objectives, and assignments.
Key points to consider:
Generally, a course can only be used to meet the requirements in one area unless a Board specifically indicates it can be used in more than one area.
Generally, can align if at least 50% of the course addresses the content area.
Check for language as to whether courses or credits need to be within the degree program or not.
Examples
Accounting
Typically, an applicant will need 150-semester credits (undergraduate or graduate) to fully meet requirements for a CPA license. Some states have a 120-semester credit requirement to allow an applicant to sit for the exam. U.S. jurisdictions vary in the number of courses and credits required to cover a specific content area or topic. For example, jurisdictional requirements vary between 27 to 36 semester credits in accounting courses and some states require a specific business ethics course.
Example from North Dakota
NDAC 3-01-02-01(2)
“Accounting concentration” means twenty-four semester credits or equivalent of accounting courses, plus twenty-four credits of other business courses.
Principles of accounting or equivalent courses do not count toward the required accounting or business courses. Up to three credits of economics credits may be included in the other business courses.
Example from Illinois
From the Board's website
Total Hours: Completion of 150 semester credit hours
Accounting Hours: 30 semester credit hours in accounting that include Managerial Accounting, Financial Accounting, Taxation and Audit.
Business Hours: 24 semester credit hours in business that include 2 semester credit hours in Business Communication and 3 semester credit hours in Business Ethics.
Professional Counselor
U.S. States and Territories typically require an applicant to hold a graduate degree from a counseling program of 48- or 60-semester credits overall with a specific list of course areas required. Many states/territories require or accept a program accredited by CACREP. States that do not will often include the CACREP eight common core content areas in their educational requirements. Beyond the eight common core content areas, jurisdictions may add other educational requirements. These may be courses or training in topics such as technology assisted counseling, psychopharmacology, addictions counseling, crisis or trauma counseling, and human sexuality.
Example from Wisconsin
Wis. Admin. Code MPSW § 14.01
In addition to 38 semester hours meeting other required areas (e.g., practicum, internship, common core content areas), at least 3 semester hours in each of the following:
Crisis and trauma counseling
Abnormal behavior and psychopathology
Addictions counseling
Family, partnership, and couples counseling
Example from Nevada
Nev. Admin. Code 641A.085
In addition to thirteen other courses required:
At least one course in abuse of alcohol or controlled substances.
At least one course in couples counseling.
At least one course in family systems.
At least one course in crisis or trauma.
At least one course in grief or loss.
HELP is available
Not every professional licensure type will have specific curriculum requirements. For those that do, we can HELP your programs understand and communicate the requirements to students. Let us know if you want HELP!
References
Federal regulation and law
34 CFR 668.43(a)(5)(v) - Institutional Information (public notifications for programs leading to professional licensure or certification for all modalities)
34 CFR 668.43(c) - Institutional Information (individualized notifications for programs leading to professional licensure or certification for all modalities)
34 CFR 668.71 - Misrepresentation - Scope and specific definitions
34 CFR 668.72 - Misrepresentation – Nature of educational program
Public Law 116-315, Section 1018 - Additional licensure disclosure requirements for students utilizing GI Bill or other VA funding.
SARA Policy
Resources