On June 28, 2024, President Rothman approved the interim policy action SYS 100-09, Interim: “Professional Licensure Programs: Determining Student Location” Policy Amendments. This interim policy action temporarily amends the definitions applied to this policy. See Section 5. Definitions for the amended definitions. The interim policy action will expire on January 1, 2025 or upon the approval of the full revisions to this policy, whichever is sooner.
Original Issuance Date: June 30, 2020
Last Revision Date: June 30, 2020
1. Policy Purpose
Under 34 CFR Sec. 668.43, new regulations have been adopted that create new disclosure requirements for professional licensure programs regardless of the mode of delivery in that the rules apply to both face-to-face and distance education programs. Per the new rules, institutions are required to determine the states in which a student and prospective student is located for the purpose of disclosing state-specific professional licensure information to students based on the state in which a student is located. This policy is necessary to provide a general structure under which institutions shall determine a student’s location for purposes of complying with the new rules. Adherence to the new federal regulations is a condition of Title IV eligibility (i.e., the ability to offer federal student aid). This new requirement goes into effect on July 1, 2020.
2. Responsible UW System Officer
Vice President for Academic and Student Affairs
3. Scope
This policy applies to all UW System institutions and their academic programs leading to professional licensure, regardless of mode of delivery.
4. Background
In 2019, the U.S. Department of Education revised the federal regulations initially established in 2016 for institutions that offer distance education in regard to state authorization, notifications and disclosures. The 2019 rules require institutions to create a written process for determining a student’s location for both Title IV verification purposes as well as state-specific disclosures related to whether the academic programs meet the professional licensure requirements in states where prospective and enrolled students are located, regardless of modality.
5. Definitions
The interim policy action SYS 100-09, Interim: “Professional Licensure Programs: Determining Student Location” Policy Amendments, establishes the following definitions in compliance with 34 CFR Sec. 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.
Location: At the time of initial enrollment in a professional or occupational licensure 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 in a program offered exclusively through distance education will be considered located at their current address listed on their official application and/or acceptance into the program.
Professional Licensure or Certification 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.
6. Policy Statement
Institutions are required to determine the states in which its students and prospective students are located for the purpose of disclosing state-specific professional licensure information. Institutions shall establish a written process to determine a student’s location at the time a prospective student seeks information about an academic program leading to professional licensure, or a student enrolls in, and/or an existing student notifies the institution of a change of address, for purposes of issuing the required disclosures under the new rules as to whether the institution’s academic program, regardless of modality, fulfills the professional licensure requirements of states in which the prospective student or enrolled student is located. This written process shall include, at minimum, the following:
- A written process as to how a student’s location is determined;
- A documented change of address process for currently enrolled students and timeframe for disclosing any academic program requirement changes if a student has moved to a different state; and
- A consistent application of these policies and procedures regarding student location to all students, including students enrolled in face-to-face programs.
7. Related Documents
8. Policy History
This is a new policy created to assist UW institutions in complying with the requirements of the 2019 new federal regulations related to professional licensure and determining a student’s location. The policy was initially approved on June 30, 2020.
9. Scheduled Review
This policy will be reviewed in June 2025 or sooner if the federal regulation is updated or changed.