Professional Licensure Notifications: What You Need to Know Before July 1, 2024

Institutions that offer educational programs leading to a license or certification must consider the additional state and federal statutory and regulatory responsibilities created to ensure that students can pursue their career goals after completing the educational programs of the institution. New Federal regulations raise the bar of responsibility for institutions beyond current regulations simply requiring notifications to prospective and enrolled students.

Effective July 1, 2024, in order to serve students in states for a program leading to a license approved to offer Title IV federal financial aid, the institution must satisfy state educational requirements for a license where the institution is located. Additionally, and a more complicated requirement, in order to serve a student in a state, the institution must satisfy state educational requirements in the state where the student enrolled in distance education is located at the time of initial enrollment. There is a Plan B option in regulation if the institution does not satisfy state educational requirements by obtaining an attestation from the student that the student intends to seek employment in another state for which the institution satisfies state educational requirements in that state. However, the institution must consider this Plan B option offered in regulation very carefully as it requires clear processes and documentation. 34 CFR 668.14(b)(32)(ii).

The public policy reasoning behind these regulations points to each state and profession as having varied educational requirements, which means that students are at risk of not completing the necessary educational requirements in a state to obtain a license or certification. It is no longer acceptable to place sole responsibility on the student to research the requirements in a state, as the stakes are too high.

Notifications are still required and are considered by the U.S. Department of Education as complementing what is required in the new regulations. The notification regulations were not significantly modified effective July 1, 2024. See 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c).

This Closer Conversation discussed how these changes may affect your institution. Topics of discussion included:

  • Required processes for an institution to be in compliance
  • Certification Procedures – Program Participation Agreement
  • Satisfying state educational requirements
  • Attestations
  • Notifications requirements
  • Which programs must meet the requirements?
  • Any impact on compliance with SARA Policy

View our professional licensure resources for information on the topic.

Discussion Leaders:

Cheryl Dowd

Senior Director, State Authorization Network & WCET Policy Innovations

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