Certifying Compliance in an Uncertain Landscape: Survey Findings on the Impact of Professional /Licensure Requirements

Professional licensure compliance often operates behind the scenes, but its influence on higher education has grown in recent years. It can shape which programs institutions offer, where students are able to enroll, and how institutions evaluate regulatory risk. The State Authorization Network’s (SAN) new report, Between the Lines, Behind the Work: Survey Findings on the True Scope of Licensure Compliance, provides a clearer view of how this work is evolving and why it warrants broader attention. Drawing on national survey data, the report shows that licensure compliance is becoming a continuous and resource-intensive institutional function, with implications for student access, institutional capacity, and long-term planning.

Why This Matters Now

Professional licensure compliance differs from many regulatory areas because of its breadth and variability. Institutions must navigate highly specific and often changing requirements across multiple states, professions, and programs. Teams track updates from numerous licensing boards, compare those requirements against program curricula, and maintain accurate public and direct disclosures for prospective and enrolled students.

In 2024, federal certification requirements changed how this work fits into institutional practice. Institutions are now required to certify, at the time of initial enrollment, whether a program meets the educational requirements for licensure in the state where each student is located. If a program does not satisfy those educational requirements, the institution generally may not enroll the student in that program for that location.

Because certification is incorporated into an institution’s Program Participation Agreement with the U.S. Department of Education, noncompliance could affect Title IV participation. Potential consequences may include sanctions, fines, or limits on access to federal financial aid. In addition, inaccurate information may contribute to student complaints, accreditor or state concerns, or reputational harm if students are unable to pursue licensure after graduation.

Under these rules, determinations about whether programs meet educational requirements must often be made independently because licensing boards are not typically positioned to formally validate program alignment with state educational requirements across all institutional offerings. This creates an environment in which interpretation, documentation, and consistency take on heightened importance and prompts institutions to build new internal processes and reassess how licensure compliance connects to broader operational and strategic planning. These new rules, and the evolving expectations that resulted from their implementation, provided the context for SAN’s national survey.

What the Survey Examined

The SAN report is based on a nationwide survey of institutions, conducted after the 2024 federal rules took effect. The survey explored several interconnected dimensions of licensure compliance:

• The scope and complexity of licensure compliance work
• Changes in workload and operational demands
• Enrollment and program decisions tied to licensure requirements
• Emerging institutional strategies and pressure points

Rather than isolating licensure compliance as a single function or office, the survey responses reflect how this work is experienced across institutional roles and processes. By examining these areas together, the survey captures how federal certification expectations interact with state licensure systems and institutional implementation choices.

Key Themes from the Findings

Across responses, institutions described navigating tradeoffs between access and certainty, and scalability and sustainability.

Workload Has Increased and Is Often Manual

One of the clearest patterns in the survey is an increase in workload associated with licensure compliance. Eighty-six percent of respondents reported a moderate or significant increase in workload following implementation of the new certification requirements.

Institutions frequently described spending more time:

• Researching and interpreting state requirements
• Documenting determinations for each program and state
• Updating public and direct disclosures
• Coordinating across academic units, admissions, student services, compliance, IT, and legal offices

Much of this work continues to be managed through manual processes such as spreadsheets, shared documents, and email. Many institutions reported taking on additional responsibilities without adding dedicated staff or new tools. Even modest increases in weekly time commitments were described as meaningful, particularly because licensure compliance responsibilities are often layered onto roles that already support multiple regulatory and operational functions.

Program Availability and Student Access Can Be Affected

As institutions develop systems to manage these obligations, many are also evaluating how licensure requirements influence broader program availability and student access.

The survey also indicates that professional licensure considerations are influencing decisions about where programs are available and which students can enroll. Roughly one-third of institutions (32 percent) reported restricting at least one licensure program or limiting enrollment in specific states due to licensure-related factors. Institutions most frequently described adjusting program availability in response to conditions such as:

• Limiting enrollment in states where licensure requirements are complex or ambiguous.
• Re-evaluating whether they can maintain broad multi-state or national offerings in licensure fields, as requirements in each state can vary.

These decisions are typically made to protect both students and institutions from uncertainty. However, they may reduce students’ options, particularly those relying on online or out-of-state programs, for pathways into licensed professions.

Survey responses indicate these pressures are most pronounced in nursing, teacher education, mental health, and health sciences, but respondents also reported growing compliance complexity across a broader range of programs, including accounting, social work, engineering, speech-language pathology, architecture, veterinary technology, physician assistant studies, and other applied professional fields. Teacher education programs were frequently cited as limiting enrollment to students in a small number of states, and sometimes only the institution’s home state, due to varying educator preparation licensure and testing requirements.

What This Means in Practice

The survey results suggest that robust and successful professional licensure compliance work now intersects academic planning, enrollment strategy, student support, and operational sustainability in ways that may not always be immediately visible but carry meaningful long-term implications. In practice, licensure compliance impacts where licensure-related programs can be offered and which geographic markets remain accessible, whether graduates are positioned to pursue licensure where they plan to work, and how to ensure compliance resilience and continuity with limited staff and tools.

These impacts reflect the layered nature of licensure oversight. Variations in how educational requirements are defined, interpreted, and reviewed across federal rules, state licensing structures, and institutional implementation can influence how consistently institutions are able to serve students across state lines.

What Institutions Can Do

As licensure compliance becomes more closely tied to enrollment decisions and program planning, institutions are increasingly working to move from reactive compliance toward more coordinated and sustainable approaches. Survey responses suggest that many institutions are strengthening cross-campus collaboration, improving documentation and data management practices, and developing processes designed to support both regulatory compliance and student access. The report highlights several approaches that may help institutions manage licensure obligations in more intentional and adaptable ways.

Make Licensure Compliance Visible in Institutional Planning

• Include professional licensure considerations in discussions about program development, online strategy, enrollment plans, and risk management.
• Clarify where licensure responsibilities reside, how determinations are made, and how they are reviewed over time.​

Build Sustainable Structures and Processes

• Consider centralizing or more clearly coordinating licensure-related responsibilities to reduce duplication and confusion.
• Evaluate whether current tools are adequate, and where structured systems, templates, or shared data sources could reduce manual burden and help maintain consistency.​

Use Licensure Information to Support Strategic Decisions

• Track where enrollment is limited due to licensure concerns and which programs or states are most affected.
• Factor licensure considerations and compliance workload into decisions about starting, expanding, or sunsetting programs, particularly in distance education.​

Lean on Collaboration and Shared Learning

• Engage in networks and communities of practice that share interpretations, tools, and examples of effective practices.
• Participate in broader conversations about aligning federal requirements, state licensure expectations, and institutional practices in ways that support student mobility and institutional capacity.​

Learn More

Between the Lines, Behind the Work: Survey Findings on the True Scope of Licensure Compliance offers early insight into how institutions are navigating evolving expectations for licensure compliance. It provides data that explores workload, enrollment decisions, and institutional strategies in greater detail. For those involved in program planning, distance education, student support services, compliance, or institutional oversight, the report offers a useful lens on how licensure requirements intersect with institutional practice and student opportunity.