Best Practices for Student Disclosures
In this post, we will discuss best practices for student disclosures, beginning with determining student location, and addressing both general and individual disclosures.
In June, we posted information about how colleges and universities are meeting the federal and NC-SARA professional licensure public disclosure requirements: Professional Licensure Public Disclosures: Where are they? We found most higher education institutions we reviewed were not meeting the public disclosure requirements. Specific results of this informal audit and a summary of the student disclosure requirements are provided in the June blog.
Regulations
Federal regulations (34 CFR 668.43(a)(5)(v) & 34 CFR 668.43(c)), added to the Higher Education Act, effective July 1, 2020, require institutions of higher education to:
Provide a general disclosure to prospective and enrolled students whether a program leading to professional licensure or certification meets educational requirements in each U.S. state and territory. The regulations apply to all modes of instruction: physical campus, online, or hybrid.
Provide an individualized direct written notification to:
Prospective students prior to their enrollment in the program if the curriculum does not meet the educational requirements in their state or territory or if the institution has not made a determination.
Enrolled students within 14 days of the institution’s determination that the curriculum does not meet the educational requirements in their state or territory.
Determining Student Location
Before we get to best practices for disclosures, we need to cover determining student location. Federal regulations (34 CFR 668.43(c)) require individual disclosure based on the location of the student or prospective student. The federal regulation leaves it up to the institution to set their own policy and process for determining student location.
A few important points to develop the best practice for determining student location:
Have a written policy and a documented process for determining and updating location.
Know where students are located now and intend to work after graduating. The process that will be most useful for students is knowing where they intend to seek licensure and work after graduating.
Have a process in place to determine location at time of enrollment and when a student’s location changes prior to graduation. For example: Some institutions require students to confirm physical address (location) when they register for online courses.
Best Practices for Disclosures
General
General disclosures may be on your website, in the catalog, or other public-facing places. Ideally a webpage with this information will have a clear title that is located not too many clicks deep. Remember, all places will need to be updated with any changes. This is the place where you will provide information as to whether programs advertised as leading to a certificate or professional license meets, does not meet, or has not been determined to meet U.S. state and territory requirements.
Individual
Individual direct disclosures for enrolled and prospective students need to be sent to individual students in writing (email or other electronic means) -- when -- for enrolled students, the institution has determined the program does not meet state educational requirements (now or later) within 14-days. For prospective students, prior to enrollment, when the institution has determined the program does not meet or has not determined whether the program meets state educational requirements.
Recommended categories for individual disclosures
License title
Education requirements
Earned degree (type, number of credits, specialized accreditation, board approval of program)
Clinical, practice, or experience hours (type, supervision, board approval of site)
Examination (eligible to take or have already completed and passed)
Education (specified training or coursework within degree program or prior to application)
Other items required to apply including
Minimum age
License fee
Transcript
Fingerprints
Background check
Additional training
University- and Program-specific course options to meet state educational requirements.
Examples of General Disclosures
Capella University has a robust professional licensure webpage, located at State licensure and authorization | Capella University, where they describe professional licensure and the importance of being aware of state licensure requirements; state they will provide direct disclosure information to students based on the address they have provided the university; discuss the potential impact of changing programs and relocating to another state; and, provide clear information by license-type on whether the program meets state licensure requirements along with detailed information as to how their program curriculum aligns with state educational requirements. One fault we found with this example is that Capella’s public disclosure does not include U.S. territories as required by the Federal regulation.
Western New Mexico University presents an example of best practice in the licensure disclosures for their social work programs on their website at Social Work State Licensing Disclosures (wnmu.edu). This institution provides students comprehensive information they need to know to apply for a license to practice in every state and US territory. Additionally, current and prospective students are provided with information about what courses, provided in the WNMU curriculum, can be taken to meet specified state educational requirements.
Common Public Disclosure Mistakes
Just providing links to state licensing boards; not indicating if the program meets educational requirements (or not).
Providing information obtained from an external source without understanding how the program meets the educational requirements.
Be careful of commercially sponsored webpages.
Assuming that a program meets each state’s educational requirements because it has the correct specialized accreditation.
You can also get HELP
Understanding professional licensure disclosures and completing the research required to create them is complex. In addition to being required by law it is also essential in providing the best support to your students. HELP has the expertise to navigate this work and ensure your students have the information they need to earn their professional license.