State Authorization & Compliance Information
Federal Licensure Disclosure Rules – July 1, 2020
If you answer YES to either of the questions below, your program is subject to the New Federal Disclosure Rules.
- Was the program designed to meet educational requirements for a specific professional license that is required for employment in an occupation?
- Is the program advertised as meeting such requirements?
Affected Programs
Many professions are regulated by state agencies that require individuals to obtain a license or certification as a condition of employment. States differ as to which professions are regulated in this manner, but some of the most commonly licensed occupations include those in legal services, social services, architecture, engineering, education, accounting, and healthcare. Marketing and advertising can also play a role in the applicability of these requirements. If programs are marketed as or described on program websites as leading to licensure or to a career in a licensed profession, arguably these requirements will still attach regardless of whether the academic unit actually designed the program to meet educational requirements for licensure.
Individual states sometimes have licensure disclosure requirements with language that differs from that used by the U.S. Department of Education. Thresholds for filing successful consumer protection complaints can also vary by state, and academic units should therefore exercise caution when identifying the scope of programs affected.
When the academic unit is not sure about whether a program would qualify, prospective students likely will not be sure either. To help avoid confusion, the academic unit may wish to provide clear, conspicuous language on its program description pages that serves to notify prospective students that such programs are not intended to lead to licensure in any state.
What do you need to do?
Update your program descriptions for each program with appropriate disclosure language. Please see the following help guides for assistance and examples on disclosure requirements:
NOTE: In cases where Michigan is the only state where it is known that educational prerequisites are satisfied, this state can simply read “This program was designed to satisfy educational prerequisites to licensure for [specific license/occupation] only in the state of Michigan. It has not been determined whether educational prerequisites to licensure would be satisfied in other states.”
More information on State Authorization can be found here.