Did ED just extend the new requirements to January 1, 2025?
Yesterday (April 9, 2024), the U.S. Department of Education (ED) released an Electronic Announcement that provides an opportunity for some institutions to extend the compliance timeline past July 1 for the new PPA Certification requirement for licensure progams.
Under the new PPA Certification regulation, institutions can only enroll students in Title IV programs located in “meets” states/territories (or who provide writtten attestation that they will seek license/employment in “meets” state/territory) starting July 1.
What did ED do?
ED is providing a limited opportunity for institutions with circumstances that are unique, time-specific, and outside the control of the institution that prevents compliance with the new PPA Certification requirement by July 1 to document the circumstances that prevent compliance and use that information as a defense in an enforcement action.
It is important to note that ED has not delayed the effective date of this new regulation.
Additionally, this only impacts the new PPA Certification section, not the public or direct disclosures.
Bottom line, this is not a free pass if institutions are not ready by July 1. It is also not a free pass to push off work until after July 1.
Institutions need to be engaged in researching educational requirements, comparing programs to state/territory educational requirements for licensure, and making a “meets” or “does not meet” determination for all licensure programs. If an external barrier (such as a lack of response from the licensing board/agency) prevents the institution from making a determination by July 1, the circumstances (such as repeated contact attempts without a response) should be documented and could be an acceptable defense to enforcement action.
Any institution that may face a unique, time-specific barrier to complying by July 1 will need to thoroughly and carefully document all related information before July 1. Think phone call logs, saved unanswered emails, and demonstration of reasonable efforts to make a determination using all available information.
If your institution hasn’t yet determined if licensure programs meet educational requirements for all states/territories where you are enrolling students, The Bookmark could be a great tool! You can find more information, including pricing, and schedule a demo on our website.