Original Issuance Date: June 30, 2020

Last Revision Date: June 30, 2020

1. Policy Purpose

Under 34 CFR Sec. 668.43, new regulations have been adopted that create new disclosure requirements for professional licensure programs regardless of the mode of delivery in that the rules apply to both face-to-face and distance education programs.  Per the new rules, 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 policy is necessary to provide a general structure under which institutions shall determine a student’s location for purposes of complying with the new rules. Adherence to the new federal regulations is a condition of Title IV eligibility (i.e., the ability to offer federal student aid). This new requirement goes into effect on July 1, 2020.

2. Responsible UW System Officer

Vice President for Academic and Student Affairs

3. Scope

This policy applies to all UW System institutions and their academic programs leading to professional licensure, regardless of mode of delivery.

4. Background

In 2019, the U.S. Department of Education revised the federal regulations initially established in 2016 for institutions that offer distance education in regard to state authorization, notifications and disclosures. The 2019  rules require institutions to create a written process for determining a student’s location for both Title IV verification purposes as well as state-specific disclosures related to whether the academic programs meet the professional licensure requirements in states where prospective and enrolled students are located, regardless of modality.

5. Definitions

Location:  A student’s location shall be defined as the place in which a student is currently living (e.g. current address) at the time of enrollment in a professional or occupational licensure or certification program, not the student’s state of residency.

Professional Licensure: Any reference to professional licensure shall include professional or occupational licensure programs as well as certification programs.

6. Policy Statement

Institutions are required to determine the states in which its students and prospective students are located for the purpose of disclosing state-specific professional licensure information.  Institutions shall establish a written process to determine a student’s location at the time a prospective student seeks information about an academic program leading to professional licensure, or a student enrolls in, and/or an existing student notifies the institution of a change of address, for purposes of issuing the required disclosures under the new rules as to whether the institution’s academic program, regardless of modality, fulfills the professional licensure requirements of states in which the prospective student or enrolled student is located. This written process shall include, at minimum, the following:

  • A written process as to how a student’s location is determined;
  • A documented change of address process for currently enrolled students and timeframe for disclosing any academic program requirement changes if a student has moved to a different state; and
  • A consistent application of these policies and procedures regarding student location to all students, including students enrolled in face-to-face programs.

7. Related Documents

34 CFR Sec. 668.43

8. Policy History

This is a new policy created to assist UW institutions in complying with the requirements of the 2019 new federal regulations related to professional licensure and determining a student’s location. The policy was initially approved on June 30, 2020.

9. Scheduled Review

This policy will be reviewed in June 2025 or sooner if the federal regulation is updated or changed.