Original Issuance Date:  June 28, 2024

Expiration Date: January 1, 2025, or upon approval of the full revisions to UW System Administrative Policy (SYS) 121, Professional Licensure Programs: Determining Student Location, whichever is sooner. 

1. Interim Policy Purpose 

In accordance with federal regulation, 34 CFR Sec. 668.43, institutions are required to determine the states in which a student and prospective student is located for the purpose of disclosing state-specific professional licensure information to students based on the state in which a student is located. This interim policy is necessary to comply with the new regulatory disclosure requirements as of July 1, 2024, by amending the definition of “location” to clarify that students enrolled in an on-campus program shall be considered to be located in the State of Wisconsin for disclosure purposes.   

2. Related Policies 

This policy temporarily amends portions of SYS 121, Professional Licensure Programs: Determining Student Location. 

3. Scope 

This policy applies to all UW System institutions and their academic programs that are designed and advertised to lead to licensure in a profession or occupation or certification, regardless of mode of delivery.  

4. Definitions 

This interim policy action establishes the following definitions in compliance with 34 CFR Sec. 668.43: 

Time of initial enrollment:  Unless otherwise defined by federal law, and for purposes of this policy, a university may consider the time of initial enrollment as a student’s official enrollment in a professional or occupational licensure or certification program and/or the receipt of the student’s financial commitment to the first class, semester or term required for completion of a licensure program. 

Location: At the time of initial enrollment in a professional or occupational licensure program, a student’s location shall be defined as the following:  

  • A student who enrolls in a program that holds instruction primarily at a physical location on campus (on-campus instruction) shall be considered located in the state of Wisconsin. This determination is based on the student being located (in part or exclusively) in Wisconsin while receiving instruction and enrolling in a program designed, primarily, to lead to licensure in the state of Wisconsin. 
  • A student enrolling in a program that offers instruction in a hybrid learning format will be considered located in Wisconsin. 
  • A student enrolling in a program offered exclusively through distance education will be considered located at their current address listed on their official application and/or acceptance into the program.  

Professional Licensure or Certification Program:  An educational program that is designed to meet educational requirements for a specific professional license or certification that is required for employment in an occupation or is advertised as meeting such requirements. Any reference to professional licensure shall include professional or occupational licensure programs as well as certification programs. 

5. Interim Policy Statement 

To comply with the revised federal requirements, Section 5 of SYS 121, Professional Licensure Programs: Determining Student Location, is being temporarily amended so the policy utilizes the definitions as written in this interim policy action. These definitions are designed to: 

  • Define “time of initial enrollment” as is necessary in determining student location; 
  • Clarify the definition of “location” to determine the location of students who enroll in F2F professional licensure or certification programs depending on the modality of the program; and 
  • Clarify the definition of “professional licensure” by amending the term to “professional licensure program” and adding additional information about the purpose of such programs. 

    6. Supplemental Documents 

None listed.