[S-SARA] Professional Licensure Disclosure Question

Thu Jul 9 11:43:56 CDT 2020

Dear Kyle –

Good afternoon.  I hope you are well and healthy during these challenging times.  This is part of an email that I sent to our institutions in North Carolina.  There is probably more information here than you asked for, but I wanted to provide some context.  The answer to your specific question is below in yellow highlight and specifically the paragraph in bold/italicized font.

Federal (DOE):
The institution must make general disclosures for every state and territory when determining if the institution’s professional licensure degree program curriculum meets the educational requirements of those states and territories.  The policy rationale is to supply information to students, who are reviewing the institution, so the students can make informed decisions about participating in the program at the institution.  The fact that your institution does not have current students or incoming students from a specific state is irrelevant.

Additionally, these disclosures must be made for degree programs that lead to professional licensure for ALL modalities or modes of educational delivery.  This includes distance education programs, hybrid programs, and face-to-face programs.  The only way to truly avoid this regulation is to discontinue offering degree programs that lead to professional licensure altogether.

34 CFR 668.43(a)(5)(v) – GENERAL DISCLOSURES*
For All modalities, disclosures must be made if the institution’s degree programs are:

  *   "designed" to meet educational requirements for a specific professional license or certification that is required for an occupation, or
  *   "advertised" as meeting professional licensure educational requirements in a state for that occupation.

*Please note that disclosures are not based on whether the degree program actually leads to a professional license or certificate (i.e., a fully online RN-to-BSN program).  If the program is designed or advertised to meet professional licensure criteria required for an occupation, disclosures must be made.

34 CFR 668.43(c) – DIRECT DISCLOSURES
For All modalities,

  *   Prior to enrollment, direct disclosure is made if the program does not meet OR the institution has not made a determination whether the program meets education requirements.  The regulations state that "regarding the timing of these disclosures, the Department expects that the institution will provide this disclosure before a student signs an enrollment agreement or, in the event that an institution does not provide an enrollment agreement, before the student makes a financial commitment to the institution."
  *   If the student is enrolled in a program and the institution makes a determination that the program does not meet educational requirements in the state where the student is located, the institution has 14 calendar days to notify the student.
  *   Upon request, the institution must document for the Dept. the basis of the institution’s determination of the programs and of student location per 34 CFR 600.9(c).

Hope this helps.  If you have further questions, feel free to contact me.

Take care,
Terrence

-----Original Message-----
From: S-SARA <s-sara-bounces at lists.onenet.net> On Behalf Of Jessie Walker
Sent: Thursday, July 9, 2020 11:57 AM
To: s-sara at lists.onenet.net; julie.woodruff at tn.gov
Subject: Re: [S-SARA] Professional Licensure Disclosure Question

Good Morning Kyle,

Many of our schools have been posting all of them in terms of their listing.

For example - http://www.uamont.edu/pages/academics/professional-licensure-disclosures/

Jessie J Walker, Ph.D.

Senior Associate Director for Academic Affairs/Research & Analytics

Arkansas Department of Education

Division of Higher Education

 (office)501-682-1602 |  Jessie.Walker at adhe.edu<mailto:Jessie.Walker at adhe.edu> | www.adhe.edu<http://www.adhe.edu>

-----Original Message-----

From: S-SARA <s-sara-bounces at lists.onenet.net<mailto:s-sara-bounces at lists.onenet.net>> On Behalf Of Foster, Kyle

Sent: Thursday, July 9, 2020 10:42 AM

To: s-sara at lists.onenet.net<mailto:s-sara at lists.onenet.net>; julie.woodruff at tn.gov<mailto:julie.woodruff at tn.gov>

Subject: [S-SARA] Professional Licensure Disclosure Question

Good morning, S-SARA colleagues.

This is not a directly SARA-related question, but I'm sure someone in our very knowledgeable group knows the answer.  Regarding the new regulations on disclosure of professional licensure eligibility: Some of our institutions have RN-to-BSN programs wherein students already have to be licensed RNs in order to be admitted to the program.  Since it is a post-licensure program, does anyone have any insight on whether these institutions would still need to make general or direct disclosures to students in these programs?  Any feedback is appreciated!

Kyle

Kyle Foster, Ph.D.

Assistant Vice Chancellor for Academic Affairs Oklahoma State Regents for Higher Education

655 Research Parkway, Suite 200 | Oklahoma City, OK 73104<https://goo.gl/maps/nMc3YG81uo72>

P: +1 405 225 9163 | F: +1 405 225 9300 | E: kfoster at osrhe.edu<mailto:kfoster at osrhe.edu<mailto:kfoster at osrhe.edu%3cmailto:kfoster at osrhe.edu>>

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