Academic Affairs: Professional Licensure Programs Disclosures

Last Updated

Intent

This statement outlines action required to comply with federal requirements outlined in 34 CFR § 668.43 as outlined in UW System Interim Policy #100-09 and UW System Administrative Policy 121 (SYS 121) by July 1, 2024. Compliance with these requirements is a condition of Title IV eligibility (the authorization to offer federal financial aid).
Scope: This procedure applies to all professional licensure programs at UW-Eau Claire (see definition below).

Definitions

UWS Interim Policy #100-09 establishes the following definitions in compliance with 34 CFR § 668.43.
Time of initial enrollment:  Unless otherwise defined by federal law, and for purposes of this policy, a university may consider the time of initial enrollment as a student’s official enrollment in a professional or occupational licensure or certification program and/or the receipt of the student’s financial commitment to the first class, semester or term required for completion of a licensure program. [Note: this differs from admission to the university or declaration of a major or pre-major]
 
Location: At the time of initial enrollment in a professional or occupational licensure or certification program, a student’s location shall be defined as the following: 
  • A student who enrolls in a program that holds instruction primarily at a physical location on campus (on-campus instruction) shall be considered located in the state of Wisconsin. This determination is based on the student being located (in part or exclusively) in Wisconsin while receiving instruction and enrolling in a program designed, primarily, to lead to licensure in the state of Wisconsin.
  • A student enrolling in a program that offers instruction in a hybrid learning format will be considered located in Wisconsin.
  • A student enrolling exclusively in distance education will be considered located at their current address listed on their official application and/or acceptance into the program. 

Professional Licensure Program:  An educational program that is designed to meet educational requirements for a specific professional license or certification that is required for employment in an occupation or is advertised as meeting such requirements. Any reference to professional licensure shall include professional or occupational licensure programs as well as certification programs.
 
The following definitions also apply:
Prospective student: Refers to a student who has made contact with a program representative to learn about program requirements.
Formal receipt of information regarding change of location: Students are asked to verify their addresses each term when they register. Students may also update their local address at any time through self-service in CampS. Either of these constitutes formal receipt of the change of location.

Requirements

The regulations require that for all programs leading to licensure, the university must: 
  • Certify that programs leading to professional licensure satisfy all requirements for licensure or certification in all states where students are located at the time of initial enrollment. If programs do not meet requirements or the university is unable to determine if they meet the requirements in particular states, the institution may not enroll students from those states in the program. Such students may be enrolled if they sign an attestation that they intend, after completing the program, to seek employment where the program does meet requirements.
  • Provide the following general disclosures 
    • A list of all states for which the institution has determined its curriculum meets the state education requirements for initial licensure or certification
    • A list of all states for which the institution has determined that its curriculum does not meet the state educational requirements for initial licensure or certification
  • Provide the following individual written disclosures: Email is an appropriate form of disclosure as long as it is an individualized email and not an email blast
    • To meet initial requirements, all programs must provide individualized disclosures to all current (as of September 2, 2020) students who are located in a state for which the program does not meet requirements or in a state for which requirements have not been determined.
    • An individualized disclosure to prospective students if a program does not meet the educational requirements for initial licensure or certification or if the institution has not determined whether the program meets requirements in the state in which the student is located. 
    • An individualized notification to current students within 14 calendar days of making a new determination that a program does not satisfy educational requirements for initial licensure or certification.

Procedures

Change of Address: Students will follow the established policy for change of address found at: https://kb.uwec.edu/article/editing-your-addresses/

Identifying Student Location: Program directors for distance education programs, or in-person programs offering a fully online course during the first semester must have a process for checking student location prior to admission to program.

Enrollment Decisions: At the time of admission to an online program that does not meet requirements in all states, students in “does not meet” states will be informed that they are not eligible for admission to the program. If they express interest in seeking employment after completion in a state where the program does meet requirements, they will be invited to complete an attestation form available from the program director. 

General Disclosures: General disclosures will be maintained on the UW-Eau Claire website. Licensure information is located on the Academic Program Page for each program: https://www.uwec.edu/academics/majors-minors/.

Individual Disclosures: Individual disclosures will be the responsibility of the educational programs. Prospective program students located in a “does not meet” state will be provided with a disclosure indicating that fact. Each term online programs will verify formal changes of location and when necessary, notify via individual email each student newly located in a state that does not meet or for which information has not been verified. If the yearly verification of licensing information reveals changes, programs will, within 14 days, disclose that information to students located in affected states.

On-campus instruction program students enrolled in online program courses: Emerging advice from the Department of Education indicates that if a student is enrolled in a fully or primarily on-campus program AND is enrolled in fully online program course in the first semester of the program AND is located in “does not meet” state they may be considered to be located in a “does not meet” state and therefore should not be enrolled unless they sign an attestation. 

Updating Licensure Information: On June 1 of each year, a representative of academic affairs will contact chairs or directors of programs leading to licensure to request verification of licensing information. Chairs or directors will work with IMC to update Academic Program Pages prior to July 1. 
 
Procedure updated 6/28/24 to comply with new federal regulations