Licensure Disclosures and Third-Party Providers: Are You Asking the Right Questions?
As your institution works to meet the requirements of SARA Policy 5.2 for professional licensure disclosures—especially for non-Title IV courses—there’s a critical blind spot you can’t afford to ignore:
Do your third-party course providers know whether their curriculum meets licensure requirements across states?
Here’s the bottom line: If your institution offers courses or programs that may lead to licensure, you are responsible for accurate disclosures—regardless of who developed the content.
And yet, many colleges and universities are offering continuing education and certificate programs built entirely by third-party providers like Ed2Go, MindEdge, CareerStep, and others—without clarity on whether those offerings meet the educational requirements for licensure in various states.
That puts your institution—and your students—at risk.
SARA Puts the Responsibility on You—But Providers Must Be Held Accountable
Under the new SARA Policy 5.2, institutions must disclose whether a course or program does or does not meet educational requirements for licensure in every U.S. state or territory where students are located. This includes all non-Title IV offerings, even non-credit offerings.
Third-party vendors often build and own the curriculum for these non-credit offerings—but they aren’t always doing the homework when it comes to licensure alignment.
As the institution, you can’t afford to assume they’ve got it covered.
What You Can Do Right Now
If your institution uses a third-party provider for any offering that could lead to licensure, here are three questions to ask today:
Do your courses meet educational requirements for licensure?
Which states have you reviewed, and what were your findings?
Can you provide documentation or curriculum comparisons that support your answer?
If a vendor claims their program “meets licensure requirements,” ask how they know. Push for details. Push for documentation.
Not Sure Your Vendor Gets It?
Hopefully you are already using The Bookmark to stay up to speed on state licensure requirements—but your third-party providers probably aren’t.
That’s why it’s critical to point them to this resource.
The Bookmark can help third-party providers:
Understand educational requirements for licensure across states
Improve the accuracy of the information they provide to institutions
Become a stronger, more compliant partner for your programs
👉 Share information about The Bookmark with your providers and make sure they’re equipped to support your compliance efforts.
Final Word
Institutions can no longer afford to treat third-party curriculum providers as “plug and play.” If you’re offering these courses under your name, you’re responsible for ensuring they meet licensure disclosure requirements.
Make sure your providers are part of the compliance conversation—not a compliance liability.
Need help starting the conversation or doing the review? That’s what we’re here for.
When this was published, the impact of SARA Policy 5.2 was still taking shape. Since then, NC-SARA has provided important clarifications, offering a clearer roadmap for implementation. Explore our latest blogs for the most up-to-date insights and guidance. Learn more.
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