91�ֿ�

Professional licensure disclosures under the 2019 Federal rules are an important consumer-protection requirement. Students who enroll in a 91�ֿ� 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.

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 91�ֿ� 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.

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.

91�ֿ� 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.

No, the disclosure information is only required for programs that are designed to lead or marketed/advertised as leading to professional licensure that is required for employment in an occupation.

Yes, however, as soon as you have updated information, you will need to notify the Office of Curriculum Services so the general disclosures may be updated. Being out of compliance with the 2019 Federal rules will put 91�ֿ�’s financial aid eligibility at risk.

"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.

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.

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.

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.

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.

In many cases, the process to be licensed or certified happens after the student completes the 91�ֿ� program. Therefore, it can be argued that it’s not required for a graduate of any 91�ֿ� 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.