State Authorization for Faculty and Staff

For Faculty: Professional Licensure and Certification Disclosures

NOTE: Federal regulations require disclosures for programs leading to licensure or certification; for brevity’s sake, the term “licensure” is used, but be aware that the regulation includes certification.

What is a “professional licensure” program?

A professional licensure* program is an academic program that is designed, marketed, and/or advertised to meet the educational requirements

For a specific license or certification and
Is required for employment in an occupation

What is a professional licensure disclosure?

A professional licensure disclosure is a requirement by the U.S. Department of Education for all colleges and universities to communicate publicly and directly to prospective and current students about

academic programs that will or will not fulfill educational requirements for specific professional licensure that is required for employment in that field and
academic programs that meet or do not meet the education requirements for licensure for each state and U.S. territory, regardless of the delivery mode of the program.

The regulations are published in the Code of Federal Regulations, , section (a)(5)(v) and section (b).

How will I know if my program needs a disclosure?

Please answer the following questions:

Are practicing professionals in your program’s field licensed or certified?
Is a specific license or certification required to practice in that profession?

If you answered YES to either of the questions above, your program will need a disclosure.

If my program needs a disclosure, what do I need to do?

Research the professional licensing requirements for each state to determine whether your program falls within that state’s regulatory oversight for professional licensure. Each state has different occupation standards requiring a professional license or certification. Some occupation examples include P-12 teachers, nurses, mental health counselors, and social workers. The licensing boards have educational criteria that an academic program must meet for a graduate to be eligible for licensure, as well as non-educational criteria for individuals to meet to be eligible for licensure (e.g., criminal background check). It is the responsibility of the program’s academic unit to know the professional licensing standards for each state where their graduates may seek a license in the field.
1. List of State Licensing Boards
Determine if your program either (a) meets those requirements or (2) does not meet those requirements to be licensed in that state. Please note that this eligibility may require state board approval of your program.
Complete the form below:

Frequently Asked Questions

Why are disclosures being required?

Professional licensure disclosures under the 2019 Federal rules are an important consumer-protection requirement. Students who enroll in a �鶹��Ƶ program that is designed to lead to professional licensure have an expectation that the university will honor its agreement by providing a program that will actually allow them to be eligible for licensure in the state where they plan to live.

Failure to communicate licensure eligibility in each state may lead to negative employment repercussions for our students as well as damage to our reputation.

What happens if I do not provide this information by the July 1 deadline or not at all?

To comply with the July 1 deadline, your program(s) will be listed as “not yet made a determination” for each state, except for Ohio. While this may appear to be an efficient approach to avoid due diligence, in the near future, all �鶹��Ƶ public disclosures must be full and accurate, or else we may face claims of misrepresentation by Federal and state regulators, which carry serious penalties and are highly attractive to whistleblower actions, as well as Federal Trade Commission investigations and lawsuits from students.

A benefit to providing the information is a marketing advantage you will have with prospective students who will be able to make better informed educational and career decisions as a result.

What if I do not know if my program meets the licensing requirements in other states?

If you are initially unsure of the licensing requirements and the status of your program(s) in other states, it may be advisable to select the no determination option while you conduct the research. As soon as you have updated information, please notify the Office of Curriculum Services so the general disclosures may be updated.

With so many professions with licensing boards in each state, a compendium of all licensing board requirements for all professions is a tall order. However, there are several resources available to get you the contact information to reach the state boards.

What happens if �鶹��Ƶ does not have a public disclosure for my program?

�鶹��Ƶ is an institution that receives Title IV funding under the Higher Education Act. As such, we must operate in compliance with the rules or risk losing eligibility for such federal funding. It is anticipated that the U.S. Department of Education will be auditing professional licensure disclosure compliance as part of institutional program reviews. In addition, the requirement of professional licensure disclosures is one of the main consumer protection provisions under the Higher Education Act and, thus, will likely be under scrutiny by both consumer groups and student advocates.

What do the following responses mean?

"does meet"

You have determined that your program's curriculum meets the state's educational requirements for licensure or certification to professionally practice in that state. In other words, a graduate of your program who can professionally practice in Ohio moves to another state and is able to practice without needing to complete additional requirements.

"does not meet"

You have determined that your program's curriculum does not meet the state's educational requirements for licensure or certification to professionally practice in that state. In other words, a graduate of your program who can professionally practice in Ohio moves to another state and is not able to practice until additional requirements are completed. Those additional requirements may include a specific state examination, letters of recommendation and additional coursework and/or practical experience.

"no determination"

You have not yet been able to confirm that your program's curriculum meets/does not meet the state's educational requirements for licensure or certification to professionally practice in that state.

What if this is too much work? What if I can't complete this in a short time when I know the information may change often?

The Federal requirement does involve research of professional requirements for every state and U.S. territory. That is why we gave program coordinators no deadline. To meet the 1 July 2020 deadline imposed by the U.S. Department of Education, we were allowed to answer “no determination made” for every state except Ohio for most of the programs. That is fine for now, but going forward, that answer must be updated to remain in compliance for federal financial aid eligibility. We will incorporate a review during the annual catalog page proofs. Therefore, we will be coming to program coordinators for an update each year, starting in March 2021. WCET/SAN has an , with tips and resources, that you may find helpful when starting this project.

Shouldn't this be the responsibility of the student, not me, to know what other states require for licensure (or certification)?

The U.S. Department of Education has ruled that it is the responsibility of institutions to determine whether their curriculum meets a state’s educational requirements. The department stated its reasoning that students may not have access to the necessary information to make the determination without assistance from program experts at the institution.

My professional association says we do not need to collect this information, and it’s acceptable to just notify students that some states may have additional requirements, and they should contact the state for more information.

That may have been true under the 2016 rules, where public disclosures were limited to online-only programs. However, in November 2019, the U.S. Department of Education amended the rule to apply to all programs offered via all deliveries that are designed for professional licensure or certification. These new regulations can be found in . If you have information about the additional requirements mandated by each state, we greatly encourage you to add a statement to your program’s webpage, and we can add to the professional licensure website.

My program is nationally accredited (or has a national exam); therefore, my program is recognized by all states.

While a specific profession may have agreed upon a national licensing exam (or accreditation), it is up to each state to decide whether it accepts the exam or not. For some professions, some states may use their own process, even when a “national” exam exists, or have additional educational expectations beyond passing the exam. The question to answer: If a graduate of my program, who can professionally practice in Ohio, moves to X state, can that person professionally practice immediately in that state? If the answer is no, a public disclosure is required.

Since students in my program are encouraged, but not required, to sit for the exam to be licensed (or certified), do I need to complete a disclosure?

In many cases, the process to be licensed or certified happens after the student completes the �鶹��Ƶ program. Therefore, it can be argued that it’s not required for a graduate of any �鶹��Ƶ program designed for licensure/certification to take that step to be licensed/certified. The question to answer: Can a graduate of my program professionally practice in the occupation without a license or certification? If the answer is no, a public disclosure is required.

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