One of the most common and consequential questions we hear from institutions is deceptively simple:
What actually counts as an educational requirement for licensure?
On the surface, this sounds straightforward. In practice, it is where many institutions get tripped up, create inconsistency across programs, or unintentionally increase risk.
The confusion usually stems from blending two very different categories of licensure requirements:
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Educational requirements that determine whether a program “meets” or “does not meet” licensure standards, and
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Additional steps required for licensure that are not educational requirements, but still matter deeply to students
Understanding the difference and communicating it clearly is essential for compliance, transparency, and student trust.
What Counts as an Educational Requirement?
Educational requirements are the components that must be completed as part of the academic program in order for a graduate to be eligible for licensure.
These typically include:
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Required coursework or curriculum content
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Required in-program clinicals, practicums, student teaching, internships, or other supervised experiences
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Required competencies that must be completed before graduation
If a requirement must be completed while a student is enrolled in the program, it should be factored into the “meets” or “does not meet” determination–these are the educational requirements.
What Does Not Count as an Educational Requirement (But Still Matters)?
Many licensure pathways include steps that occur after graduation or during the application process. These are often mistaken for educational barriers when they are not.
Common examples include:
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Exams (including jurisprudence exams)
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Background checks
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Specific trainings, such as mandated child-abuse reporting or CPR
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State-specific content courses that can be completed post-graduation (i.e. state history or constitution course)
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Supervised experience required after graduation or specific work experience
These are license application requirements, not educational requirements.
If a program meets the educational requirements, but does not include specific training or required work experience, the correct determination is still “Meets.”
That said, ignoring these requirements altogether creates a different kind of problem.
Why Disclosure Still Matters (Even When You Mark “Meets”)
Federal Title IV regulations and SARA Policy 5.2 focus narrowly on educational requirements. But students experience licensure as a full pathway, and are typically not aware of the license application requirements.
When institutions fail to disclose post-graduation requirements or those factors outside of the educational program:
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Students are surprised by additional costs, delays, or hurdles
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Advising gaps emerge across departments
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Institutions face reputational and risk management issues
This is why we often recommend additional disclosures, even when they are not required to meet U.S. Department of Education Title IV regulations or SARA policy.
Examples where this is especially important include:
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State-specific post-graduation courses (such as state history or suicide prevention requirements)
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Jurisprudence or state-specific exams
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Post-graduation supervised experience
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Criminal history limitations
These disclosures support informed decision-making and reduce downstream risk for both students and institutions.
Additionally, the U.S. Department of Veterans Affairs requires these types of additional disclosures for the state or U.S. territory where the institution is located for all licensure programs. And any institution offering a Pell-eligible Prison Program must inform students if their program leads to an occupation that typically prohibits licensure for individuals with criminal records.
Special Scenarios That Often Cause Confusion
A few situations come up repeatedly:
Requirements Completed After Graduation
If a state allows certain requirements to be completed after graduation but before licensure, the program can still be marked “Meets” for educational requirements. Transparency about the remaining steps is key. The U.S. Department of Education addresses these scenarios in the Certification Procedures – Questions and Answers (LDR-A8).
Provisional Licensure
If a state allows provisional licensure and the ability to be employed while a graduate completes additional requirements, the program generally meets educational requirements. A specific example is provided for teachers in the U.S. Department of Education’s Certification Procedures – Questions and Answers (LDR-A8).
No License or Certification Exists
If a state does not offer licensure for a profession, there are no educational requirements to meet. In these cases, institutions should clearly disclose that no license exists in that jurisdiction, rather than forcing a “meets” or “does not meet” framework that does not apply. A specific example is provided for bachelor’s degrees in social work in the U.S. Department of Education’s Certification Procedures – Questions and Answers (LDR-A10).
National Credentials Instead of State Licensure
When a private-issued certification is the professional benchmark, and no state license is required, the absence of state licensure should be clearly disclosed, along with an explanation of how the program aligns with the private-issued certification. A licensure program is one that leads to a state- or territory-issued credential required for employment in that profession or occupation.
Consistency Is Not Optional
One of the biggest risks we see is inconsistent criteria for determinations across programs within the same institution.
This often happens when:
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Program chairs or academic leaders interpret requirements differently
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Educational and license application requirements are blended together
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Disclosure strategy is unclear or overly rigid
Institutions benefit from shared definitions, centralized guidance, and clear internal training so that similar requirements are treated consistently across departments. While licensure compliance is typically too much for one person to handle, it is extremely beneficial to have one person oversee and coordinate all of the determinations across programs.
The Bigger Picture
Licensure compliance is not just about checking a regulatory box. It is about helping students understand:
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Whether a program meets educational requirements
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What additional steps they will need to complete for licensure
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When and where those steps occur
Clear distinctions, thoughtful disclosures, and consistent decision-making protect students and reduces institutional risk, while building trust in an increasingly complex licensure landscape.
As requirements from the U.S. Department of Education and SARA may continue to evolve, institutions that focus on clarity and transparency – not just minimum compliance – will be best positioned to support both students and staff.
How We Can HELP
This is exactly the kind of work where institutions benefit from having both strong tools and experienced guidance.
The Bookmark gives your team a centralized, reliable place to evaluate educational requirements across states, make consistent determinations, and track some of the additional licensure steps that still need to be disclosed. It reduces the guesswork and helps ensure your decisions are grounded in verified, regularly updated data.
At the same time, many institutions find that the real challenge is not just accessing the information, but applying it consistently across programs and departments. That is where we work directly with institutions.
We can provide one-on-one support to ensure your team has a clear, consistent approach to licensure determinations and disclosures, grounded in accurate data and aligned across programs. We also work alongside you on specific licensure projects to help navigate complexity, reduce risk, and build processes your institution can rely on over time.
Need extra support? Set up a call with our subject matter expert, Kris Maul.
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