SAN Professional Licensure New Regulations FAQ
Originally developed after the SAN & WCET November 2023 webinar. Updated by the SAN Special Interest Team.
May 14, 2024
This SAN FAQ document, available for download to the right, is intended to answer some nuanced questions about new and revised Federal regulations that are effective July 1, 2024. The regulations address requirements tied to Title IV federal aid programs for institutions serving students in programs leading to a professional license or certification.
These regulations were released as final on October 31, 2023; Responsibility, Administrative Capability, Certification Procedures, Ability to Benefit (ATB).
- Certification Procedures under 34 CFR 668.14(b)(32)
- Institutional Information under 34 CFR 668.43(a)(5)(v) & 668.43(c)
Topics of the FAQ are as follows:
- Regulations
- Student Location
- Modality
- Professional Licensure Programs & Educational Requirements
- Attestations
- Defining "initial enrollment"
- Public and Individualized Notifications
Note: We thank the members of the SAN Special Interest Team for Professional Licensure for their great work in updating the FAQ document initially created following the SAN and WCET webinar in November 2023.
Disclaimer: The information and analysis in this document are our best understanding of the regulations as of the date of the document. The analysis is based upon the preamble of the Federal Register announcement of the final regulations and the email communications with the U.S. Department of Education’s designated contact for Certification Procedures. We still anticipate the FAQ document that the U.S. Department of Education stated in early 2024 and again in April 2024 that they would provide.
This analysis should not be considered to be or used as legal advice. Institutions must make implementation determinations based on the institution’s analysis practices. Legal questions should be directed to legal counsel.