Programs Leading to a License or Certification

(Revised for July 1, 2024, Federal Regulations Effective Date)

Key Institution Responsibilities:

• Seek program approval by the state licensing board, if required, in the state where the activity occurs. 
• Certify that the program satisfies state applicable state educational requirements in the state where the students are located for the program to be eligible for Title IV Federal Financial Aid per 34 CFR 668.14(b)(32).
• Provide public and individualized notifications for programs leading to a professional license or certification as required by 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c).
• Comply with SARA Policy as required by SARA Policy Manual Section 5.2.
• Comply with State laws and regulations and Federal Misrepresentation Regulations.

State Program Approvals:

• Determine state location of students participating in the courses & programs leading to a license or certification.
• Research state laws & regulations where the student is located to determine applicable requirements when serving a student in that location.
• Comply with state laws & regulations and obtain state programs approval, if required, where the student is located.

Federal Regulations: Certification Procedures (Title IV) – 34 CFR 668.14(b)(32)

• As part of the Program Participation Agreement (PPA), the institution must certify that it satisfies applicable state educational requirements:
  • Where the institution is located.
  • Where the student enrolled in distance education is located at the initial time of enrollment or where the student attests they intend to seek employment.
  • For students enrolled in programs on or after July 1, 2024.

Federal Regulations Requiring Notifications - 34 CFR 668.43 (a)(5)(v) & 34 CFR 668.43(c):

• All educational programs as described in the regulation, regardless of modality.
• Educational programs are those that are Designed or Advertised:
  • To meet state educational requirements for a specific professional license or certification
  • Required for employment in an occupation
  • Whether completion of the program is sufficient to meet state licensure requirements.
• Public/Make Available Notification where the institution has made a determination:
  • List of states where the curriculum DOES meet state educational requirements.
  • List of states where the curriculum DOES NOT meet state educational requirements.
  • List of states where the institution HAS NOT MADE A DETERMINATION. (No longer required per regulations effective July 1, 2024)
• Direct/Individualized Notifications
  • Required for Prospective Students:  if the institution indicates DOES NOT meet state educational requirements or NO DETERMINATION where the prospective student is located, a notice to that effect must go to the student prior to enrollment in the program. (prior to a financial commitment)
  • Required for Enrolled Students: if the institution indicates DOES NOT meet the state educational requirements in the location where the enrolled student is located, the notice to that effect must be provided to the enrolled student within 14 calendar days of the institution making that determination.

SARA Requirements – SARA Policy Manual Section 5.2

• SARA participating institutions must satisfy Federal requirements for notifications for programs subject to SARA Policy.  For SARA purposes, the requirements also apply to non-Title IV institutions.  Review the SARA Policy Manual for specific requirements.

For more details, please review the Professional Licensure Landing Page on the SAN website.

Note: This resource was created by the State Authorization Network (SAN), a division of WCET. Regulatory language and references are subject to change. The information should not be considered legal advice. Legal questions should be directed to legal counsel.