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Professional Licensure

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Licensure Board Approvals, State Educational Requirements, & Notifications

Additional Responsibilities for Professional Licensure Programs on all degree levels

Institutions Must:

  • Seek state program approval by the state licensing board, if required by the state board, in the state where the activity occurs. 
  • New! For students enrolling in programs leading to a license on or after July 1, 2024 - The institution must satisfy applicable educational requirements for a license in the state where the Institution is Located AND where the Student is Located at time of initial enrollment or the State where the student attests they intend to seek employment. 34 CFR 668.14(b)(32)(ii) effective July 1, 2024.
  • Provide notifications for in-person and distance education programs leading to professional licensure as required by 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c) for purposes of title IV HEA programs. (effective July 1, 2024, the institution will no longer be required to publicly provide a list of states where the institution has not made a determination about meeting state educational requirements for those states.)
  • Provide notifications as required by SARA Policy Manual Section 5.2.
  • Provide Cost of Attendance (COA):  Professional licensure, certification, or a first professional credential-An allowance for the costs associated with obtaining a license, certification, or a first professional credential, for a student in a program that prepares them to enter a profession that requires such a qualification as required by:  The FAFSA Simplification Act (116 Pub. L. 260, Division FF, Title VII) and the Consolidated Appropriations Act, 2022 (117 Pub. L. 103, Division R). 
  • Veterans Benefits - SAA will approve courses that comply with 38 CFR 21.4253(d)(9) and provide notifications as stated in 34 CFR 21.4259(e).
  • Pell for Currently Incarcerated Students - Must comply with 34 CFR 668.236(c) in 34 CFR 668.43(a)(5)(vi).
  • Comply with State regulations and Federal Misrepresentation Regulations.

* you are encouraged to read the Federal Regulations listed and SARA Manual Section 5.2 to determine applicability.


Available Resources

Federal & State Regulations

There are several different regulatory considerations for institutions about satisfying requirements and providing notifications regarding licensure and certification requirements:  Federal Regulations regarding Title IV eligibility effective July 1, 2020 and new regulations effective July 1, 2024, Pell for Incarcerated Individuals effective July 1, 2023, Federal Regulations regarding VA Benefits eligibility effective February 17, 2023, Federal Misrepresentation Regulations, and State regulations.

Federal Regulations Addressing Certification in the Program Participation Agreement (PPA) - Effective July 1, 2024 (for participation in Title IV Federal Financial Aid programs)

34 CFR 668.14(b)(32)(ii) - For ALL programs leading to professional licensure in a state, regardless of modality (face to face and distance ed.)

  • The institution must determine that each program eligible for title IV, HEA program funds 
  • Satisfies the applicable educational requirements for professional licensure or certification requirements in the State so that a student who enrolls in the program, and seeks employment in that State after completing the program, qualifies to take any licensure or certification exam that is needed for the student to practice or find employment in an occupation that the program prepares students to enter; 
  • In each state in which:
    • the institution is located; 
    • students enrolled by the institution in distance education or correspondence courses are located, as determined at the time of initial enrollment in accordance with 34 CFR 600.9(c)(2); or 
    • attests that they intend to seek employment,  
    • for each student who enrolls in a program on or after July 1, 2024.

Federal Regulations for Professional Licensure Notifications - Effective July 1, 2020 (for participation in Title IV Federal Financial Aid programs)

668.43(a)(5)(v) and 668.43(c) For ALL programs leading to professional licensure in a state, regardless of modality (face to face and distance ed.)

Public Notification - 34 CFR 668.43(a)(5)(v)

Disclosures for educational programs that are

  • “designed” to meet educational requirements to obtain a specific license or certification that is required for employment in an occupation, or
  • “advertised” as meeting professional licensure educational requirements

whether completion of that program is sufficient to meet licensure requirements in a state for that occupation. 

How to disclose 

  • A list of states where the program curriculum meets state educational requirements for licensure or certification.
  • A list of states where the program curriculum does not meet state educational requirements for licensure or certification.
  • A list of states where the institution has not made a determination. (not required after after July 1, 2024 per revised Federal regulations)


Individualized notifications - 34 CFR 668.43(c) directly to the student regarding the student's location

  • Prospective Students – if curriculum does not meet state requirements or no determination made where student is located prior to enrollment in the program (prior to a financial commitment is official guidance from the Department of Education) provide a disclosure to that effect.
  • Enrolled students - if the institution makes a determination that the curriculum does not meet state educational requirements where the student is located - 14 calendar days of that determination to notify the students where they are located provide the disclosure to that effect.
  • Disclosures of this section must be made directly to the student in writing, which may include through email or other electronic communication.


Federal Regulations for Professional Licensure Programs - Effective February 17, 2023 (for participation in Veterans Benefits)

  • Meeting instructional curriculum licensure requirements of such State:  38 CFR 21.4253(d)(9).For the State Approving Agency (SAA) to approve a course to receive Veterans Benefits it must meet certain criteria. For licensure programs, the course must meet all instructional curriculum licensure or certification requirements of such State.
  • Required Notifications: 34 CFR 21.4259(e) The SAA may disapprove a licensing and certification program if the institution fails to publicly disclose in a prominent manner any conditions or additional requirements, including training, experience, or examinations required to obtain the license, certification, or approval for which the program of education is designed to provide preparation.


Federal Regulations for Professional Licensure Programs Offered to Currently Incarcerated Students - Effective July 1, 2023 (for Pell Program Eligibility) 

  • 34 CFR 668.236(g) An eligible prison education program leading to a license must satisfy any applicable education requirements for professional licensure or certification….. in the State in which the correctional facility is located or, in the case of a Federal correctional facility, in the State in which most of the individuals confined or incarcerated in such facility will reside upon release as determined by the institution not less than annually based on information provided by the oversight entity.
  • 34 CFR 668.43(a)(5)(vi) For a prison education program, as defined in 34 CFR 668.236, notifications about State or Federal prohibitions for licensure or employment of formerly incarcerated individuals in any other State for which the institution has made a determination about State prohibitions.


Federal Misrepresentation Regulations

An institution must be aware of their communications, or omissions, to students per misrepresentation regulations.

The Federal Misrepresentation regulations state that an institution participating in Title IV HEA programs, must not engage in substantial misrepresentation.

Misrepresentation as defined in 34 CFR 668.71  includes any false, erroneous, or misleading statement or omission to a prospective or enrolled student and “substantial misrepresentation” is any misrepresentation on which a person could reasonably be expected to rely, or has reasonably relied, to the person’s determent. The  definition includes passive omissions leading to misrepresentation in addition to active statements. 

The Federal regulations go on to state in 34 CFR 668.72 that there must be no misrepresentation as to the nature of the program.  This part of the regulation specifically states in 34 CFR 668.72(c)(2) that there is to be no misrepresentation as to whether the successful completion of a course of instruction qualifies a student -

"To receive, to apply to take or to take the examination required to receive, a local, State, or Federal license, or a nongovernmental certification required as a precondition for employment, or to perform certain functions in the States in which the educational program is offered, or to meet additional conditions that the institution knows or reasonably should know are generally needed to secure employment in a recognized occupation for which the program is represented to prepare students;"


State Regulations  

Institutions should determine if there are separate requirements by state laws and regulations to offer professional licensure programs in the state.  These could include state misrepresentation regulations and other consumer protection related regulations.

SARA Requirements - Notifications

Institutions that participate in reciprocity through SARA must be aware and comply with notification requirements directed by SARA Policy.  The June 12, 2020 NC-SARA  Announcement, regarding a revision to the language of Section 5.2, states the following notification requirements that more closely align with Federal regulations:

Section 5.2 -  Programs leading to Professional Licensure

SARA has no effect on State professional licensing requirements. Any Institution approved to participate in SARA that offers courses or programs designed to lead to Professional Licensure or certification or advertised as leading to Licensure must satisfy all federal requirements for disclosures regarding such Professional Licensure programs under 34 §C.F.R. 668.43. For SARA purposes, these requirements will also apply to non-Title IV institutions.

For SARA purposes, institutions that are unable, after all reasonable efforts, to determine whether a program will meet state professional licensure requirements shall provide the student or applicant with current contact information for any applicable licensing boards, and advise the student or applicant to determine whether the program meets requirements for Licensure in the State where the student or applicant is located.


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