Between the Lines, Behind the Work: Survey Findings on the True Scope of Licensure Compliance

title page to the report "Between the Lines, Behind the Work: Survey Findings on the True Scope of Licensure Compliance". Published by the State Authorization Network (SAN).

Summary -

This report examines how institutions are managing the growing demands of professional licensure compliance following the 2024 federal certification requirements. Based on a nationwide survey, it highlights the scope, complexity, and intensity of licensure-related work across states, professions, and academic programs.

Unlike other compliance areas, professional licensure requires institutions to track and interpret highly variable state requirements, determine whether programs meet educational standards in each student’s location, and provide accurate public and direct disclosures. Under the new regulations, institutions must certify these determinations at the time of enrollment, often without confirmation from state licensing boards, increasing institutional risk and responsibility.

The findings show that licensure compliance now carries significant workload, operational strain, and potential consequences for student access. Many institutions report increased staff burden, reliance on manual processes, and difficult decisions about where programs can be offered. The report provides early insight into how institutions are responding and underscores the need for sustainable compliance practices, clearer policy alignment, and continued collaboration to protect students and support licensure pathways.

Contents -

Section 1: Introduction & Methodology
Section 2: The Scope and Complexity of Professional Licensure Compliance
Section 3: Compliance Workload Impact
Section 4: Enrollment Restrictions and Program Availability
Section 5: Institutional Strategy and Practice
Section 6: Conclusion & Recommendations
Appendix 1: Additional Data on Compliance Workload Impact (Section 3)
Appendix B: Additional Data on Enrollment Restrictions and Program Availability (Section 4)
Appendix C: Additional Data on Institutional Strategy and Practice (Section 5)

Details

Year Published: 2026
Month Published: January
Media Type: pdf

Downloadable PDF

Authors:

Kathryn Kerensky, Director of Digital Learning, Policy & Compliance, SAN
Sarah Cheverton, State Authorization and Compliance Officer for Online and Distance Learning, James Madison University

Reviewers:

Kristen Brown, Director, Online Learning & Digital Access Initiatives, University of Louisville
Miranda Hines, Associate Director, Distance Learning Administration, University of Kentucky

For inquiries or more information contact san-info@wiche.edu