No Pandemic Pause: Professional Licensure Compliance
For those of us who work in higher education, it’s no secret that higher education is highly regulated. Colleges, universities, and other higher education providers must meet a wide array of federal and state requirements to offer programs on campus or online. From time-to-time, these requirements change and institutions must update their policies and processes in order to comply.
This year, understandably, the COVID-19 pandemic and new levels of financial pressures have left many institutions feeling the weight of 2020, without anything left for new compliance measures. Unfortunately, compliance does not have a pandemic pause button.
Institutions that do not know how their programs fulfill professional licensure or certification requirements must act now in order to comply with federal and state disclosure requirements. Each day that passes, institutions risk loss of federal Title IV financial aid program eligibility, enforcement or legal action, and worst of all, poor student experiences and graduate outcomes.
Here are the basics of what colleges and universities need to know. We will be diving deeper into each area in future blog posts.
What is required?
Federal law - 34 §C.F.R. 668.43
Professional licensure related disclosures required as of July 1, 2020!
Both broad and individual direct
Institutions must indicate if the program meets educational requirements for licensure, does not meet or if the institution has not yet made a determination.
State law
Some states require specific licensure related disclosures, program approvals and/or follow State Authorization Reciprocity Agreements (SARA) policy.
SARA Policy Manual - Section 5.2
Goes beyond current Federal law.
Who is covered?
All prospective students and current students for any program designed for or advertised as leading to a professional license or certification.
Disclosure information must be based on the student’s location, as defined by the institution. Timing and updates are important!
Why should colleges and universities be responsible?
Students invest significant money and time. They deserve to know what their return on investment could be or what the limitations are, including licensure and certification possibilities.
Institutions are the experts of their curriculum. A prospective or new student should not be expected to review and compare syllabi to state licensing requirements, when they haven’t even completed a 101 course yet!
Students are mobile! Many relocate to attend a program and/or move where the job market is stronger after graduating. With more remote work and tele-health opportunities, many graduates will need to be licensed in multiple states after graduating.
How should institutions comply?
There are many great resources to help colleges and universities understand and comply with these requirements. Here are a few:
If you need HELP figuring out where to start, researching the specific state licensure requirements, analyzing your curriculum, creating a student disclosure process or auditing your current disclosures, we are here! We have successfully led programs and institutions through this complicated work, and can HELP guide you — because there is no pause button, even during a pandemic.