The Struggle and a New Solution
The Struggle: Licensure Research is Complicated, Time-Consuming, and Expensive
After working with colleges and universities of all sizes from across the U.S., it is clear to us that most do not have the people power, time, or expertise to complete the licensure research required for compliance with federal Department of Education regulations and State Authorization Reciprocity Agreement (SARA) policy.
Extensive Disclosure Requirements
Since July 1, 2020, 34 § C.F.R. 668.43 requires institutions that participate in Title IV student aid programs to disclose if their programs designed for or advertised as leading to a license meet or do not meet educational requirements in every U.S. state and territory (59 jurisdictions). This applies to all modalities of learning (face-to-face, distance, and hybrid) and all types of programs (from certificate to doctoral degree). Additionally, the Department of Education has proposed to expand institutions’ responsibilities related to licensure, including that institutions ensure programs meet educational requirements for licensure in every state/territory where students are located.
SARA Policy refers to current federal regulation and applies it to all SARA participating institutions–even if not Title IV participants. Additionally, SARA policy requires institutions to make “all reasonable efforts” to determine if a program meets or does not meet educational requirements for licensure before indicating that they cannot determine. SARA policy also requires institutions to provide contact information for every licensing board/agency in those states/territories where it cannot be determined.
Additional federal requirements apply to students utilizing GI Bill benefits under Isakson and Roe Veterans Health Care and Benefits Improvement Act of 2020. This legislation included requirements for licensure disclosures to all students for the state/territory in which they “intend” to work. Additionally, it requires institutions to disclose other non-program post-graduation licensure requirements such as professional exams, application fees, work/training minimums, etc.
Expanding Licensure Programs
Professional and occupational licensure has been growing at an exponential rate over the past six decades. In 1950, only 5% of professions led to licensure, requiring roughly 1 in 20 workers to become licensed to work (Kleiner and Krueger, 2013). By 2010, 25% of professions required licensure (Klenier and Krueger, 2013) and in 2018 roughly 43 million people held a professional certification or license (Bureau of Labor Statistics, 2019). By 2021, roughly 1 in 3 or 33.3% of all professions require licensure (State Policy Network, 2021).
The typical college and university (including a community and technical college) has at least one program and most have multiple programs that lead to licensure or certification. For example, the Minnesota Private College Council (MPCC) represents 18 private, non-profit colleges and universities. Of those 18, the number of licensure/certificate programs per institution ranges from 1 to 43, with an average of 23. The Kansas Independent College Association (KICA) represents 20 non-profit institutions that offer programs related to over 55 distinct license types, with almost two-thirds of its members offering more than 10 different licensure programs.
Significant Resources Required
In order to understand if programs meet or do not meet educational requirements for licensure, institutions must research the law in each state and territory. Because licensure is left up to states, there is no national standard for educational requirements for licensure. This results in a patchwork of varying requirements–with some professions having more similarity between states than others. After researching (and interpreting) the educational requirements, an institution needs to compare their program–in some instances down to the course and even assignment level-to know if the program meets or does not meet requirements.
Researching educational requirements for licensure takes a significant amount of time—between 2-8+ hours per state/territory for each license type. 2-8+ hours per state/territory across 59 jurisdictions (50 states, D.C., and 8 territories) adds up to 118-472 hours of research for one license-type. If an average institution has at least 10 license related programs, this amounts to 1180-4720 hours of research necessary - easily the equivalent of 1+ full time employee. This estimate does not include the additional time required to compare each program to each state/territory requirements.
Additionally, interpreting and understanding the requirements found through research takes a certain level of expertise. Accounting for this level of expertise, some institutions have estimated a cost of $22,000 per license type for the initial research and $11,000 per license type for an annual review/update. (Lewis, Klingen, and Heard III, 2022)
New Solution: The Bookmark
The Bookmark is a licensure research library — a knowledgebase of educational requirements across professions for all US states and territories. It is a comprehensive collection of all educational requirements for U.S. state/territory-issued licensure or certification.
The Bookmark’s annual fee for users is significantly less than alternatives for completing this required work (e.g., employee). The annual fee is based on the number of users at the institution, association, or organization. Enterprise-level memberships are available, offering a further discount to organizations that serve groups of institutions.
Join Higher Education Licensure Pros (HELP) LLC to learn more about this new research solution.
Click here to view the dates and register for an upcoming Information Session and demo
A series of Information Sessions are scheduled in January and February 2023. Register for a session to learn more, see a demo, and ask questions.
During these sessions, HELP experts will guide you through this new innovative tool. The information in The Bookmark provides guidance to colleges and universities to enable them to comply with licensure disclosure requirements and provide excellent student support.
The Bookmark is created by HELP through:
Review and analysis of state statute, regulation, rule, and policy
Assessment of information on board/agency website and license application materials
Communication with state board or agency to clarify requirements (when needed)
By February 1, 2023, The Bookmark will have educational requirements for over 50 license-types (e.g., social work, nursing, teaching, accountant, physician assistant, counselor), with a plan to continue adding additional license-types over time. The Bookmark will also provide interpretation of the requirements for the typical institution (e.g., on-campus, regionally accredited) as well as unique requirements for programs offering courses at a distance. The analysis needed to form these interpretations adds to the value of The Bookmark.
The Bookmark includes information for all components of educational requirements for licensure, including:
degree type
specialized accreditation
specific courses
exams
any additional educational requirements
Key features of The Bookmark
Information can be downloaded by subscribers in .csv and .pdf formats for documentation purposes and internal use.
All information is updated on an annual basis, or as soon as HELP learns of a change in state/territory requirements.
All users will receive an email whenever information is updated in The Bookmark. Users can opt out.
Changes and updates are also tracked in a history log for every state/territory for each license type.
Meeting federal and State Authorization Reciprocity Agreement (SARA) licensure disclosure requirements doesn’t have to be time-consuming, complicated, or expensive. The Bookmark is the solution to fulfill compliance needs and support students.
More more information or to become a member of The Bookmark, email us: TheBookmark@higheredlicensurepros.com
References
Certification and licensing status of the employed by industry and class of worker, 2019 annual averages, U.S. Department of Labor, Bureau of Labor Statistics, accessed at https://www.bls.gov/cps/aa2019/cpsaat52.htm
Analyzing the Extent and Influence of Occupational Licensing on the Labor Market, Journal of Labor Economics, Morris M. Kleiner and Alan B. Krueger, Vol. 31, No. 2, The Princeton Data Improvement Initiative (Part 2, April 2013), pp. S173-S202
States Reform Occupational Licensing Laws to Make It Easier for Americans to Get Jobs, State Policy Network, July 12, 2021, accessed at https://spn.org/blog/spotlight-on-legislative-sessions-job-licensing/
Realigning Professional Licensure within the 21st Century, Jennifer S. Lewis, Anne M. Klingen, & Kenneth M. Heard, III, NASASPS 2022 Annual Conference, accessed at https://nasasps.org/wp-content/uploads/NASASPS2022-HeardLewisKlingen-Realigning-Professional-Licensure.pdf