Navigating New SARA Policy Licensure Disclosures: What Your Institution Needs to Know about Non-Title IV and Workforce Courses
With the July 1 change to SARA Policy 5.2, we know many institutions have questions—especially when it comes to workforce development and professional education courses offered through third-party vendors. SARA Policy now extends licensure disclosure requirements to any non-Title IV program or offering.
By participating in the State Authorization Reciprocity Agreement (SARA), institutions have the ability to enroll students located in other states in online and distance education learning. Institutions agree to satisfy all policies when choosing to participate in SARA.
This now includes the obligation to provide licensure disclosures–both public and direct–to anyone enrolling in anything licensure-related.
This could be a program, courses or any non-credit offering. Bottom line—if the institution is offering something that is designed or advertised as preparing someone for an occupational or professional license (or any credential issued by a state/territory that is required for employment) across state lines, disclosures are a must.
Recently, Kris Maul, JD, a national subject matter expert, guided a Bookmark member through questions about how the SARA policy change impacts non-Title IV programs and offerings.
We’re sharing these insights because we know they’ll be valuable as your institution considers how these changes may affect your own offerings. Here are the main takeaways for your institution:
1. Licensure Disclosures Apply Beyond the Institution
If your institution (including any third-party vendors acting on behalf of the institution) offers workforce development courses related to occupational or professional licensure (think HVAC, real estate, or plumbing) to individuals in other states—and those individuals are not currently employed in that field—then public and direct disclosures do apply.
This means you must publicly disclose where your offering (including any third-party vendor offered courses) “meet” or “do not meet” licensure requirements and provide direct disclosures to students in states where the offering “does not meet” or where a determination has not been made.
2. Third-Party Vendor Challenges Are Common—But Compliance Is Non-Negotiable
Many institutions report that third-party vendors are unaware of licensure disclosure requirements. While this is a pain point, the responsibility ultimately falls on the institution to ensure compliance.
HELP can work with your team to navigate these complexities and develop clear communication strategies with vendors. At the end of the day, the institution will be on the hook for complying with SARA policy.
3. Blanket Disclaimers Can Prevent Misunderstandings
For courses not designed for licensure—like “Accounting Fundamentals” or “Explore a Career as a Pharmacy Technician”—HELP recommends using a clear disclaimer like:
“These courses are intended for professional development and are not designed to meet educational requirements for professional licensure or certification.”
This step helps avoid potential confusion and protects your institution from claims of misrepresentation.
4. Board Contact Information No Longer Required
In addition to the important changes we have highlighted, as of July 1, 2025, institutions are no longer required to provide licensure board contact information (like URLs) in public disclosures. However, you must still list states and territories where a licensure determination has been made, indicating if the program or offering “meets” or “does not meet” educational requirements for licensure.
Even though SARA policy no longer requires board contact information to be disclosed, providing general information on your website about licensure requirements, including links to board or association websites, can be very helpful to students. Their ability to achieve licensure after completing the program, courses or offering will only help the institution.
How HELP Supports Our Members
HELP clients get access to expertise like this through our webinars, one-on-one consulting, and The Bookmark–our exclusive database of educational requirements for licensure. For example, our national subject matter expert, Kris Maul, regularly leads sessions breaking down nuanced issues like these so your institution can stay ahead of compliance risks.
This is the kind of behind-the-scenes support and expertise our members rely on to keep their institutions compliant—and their students informed.
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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