Professional Licensure Disclosures

Policy Number: BFA-1200-003

Policy Title:  Professional Licensure Disclosures

Vice Chancellor/Associate Chancellor: Associate Chancellor, Budget and Financial Administration

Unit Responsible for Policy:  Office of Institutional Research

Effective Date: 7/1/2020

Contact: Director of the Office of Institutional Research

Policy Statement:

The U.S. Code of Federal Regulations, specifically 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c) require disclosures by institutions regarding educational requirements for programs leading to professional licensure or certification regardless of modality. 34 CFR 668.43(a)(5)(v) requires an institution to make readily available to enrolled and prospective students information about whether programs leading to professional licensure or certification meet educational requirements.

If an educational program offered by UIC 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, information regarding whether completing that program would be sufficient to meet licensure requirements in a State for that occupation is required, including—

(A) A list of all States for which the institution has determined that its curriculum meets the State educational requirements for licensure or certification;

(B) A list of all States for which the institution has determined that its curriculum does not meet the State educational requirements for licensure or certification; and

(C) A list of all States for which the institution has not made a determination that its curriculum meets the State educational requirements for licensure or certification;

A direct disclosure is required by 34 CFR 668.43(c) by the institution to the student in writing if the program leading to professional licensure or certification falls in one of the latter two categories above (the curriculum does not meet educational requirements, or the institution has not made a determination) for the State in which a student is located. In those two situations, the institution must inform the student directly of that status. This direct notification (typically by email or letter) must occur before the student’s enrollment in the program.

Alternatively, for a student enrolled in the program, if the institution makes a later determination that the program does not meet educational requirements for licensure or certification in the State where the student is located, the institution must provide notice directly to the student within 14 calendar days of making that determination. The direct disclosures must be in writing. It is anticipated that this provision would happen most often when a program loses its approval in a State.

Student location: For purposes of this policy, the student location is the State where the enrolled student resides and is based on the permanent home address entered into the UIC Banner Student Administration system.  For a prospective student, this is the State of the prospective student’s residency at the time the student has applied for admission, intends to enroll, and is then entered into the UIC instance of the (Slate) customer management system.  For students whose permanent address does not include a U.S. State or territory (e.g., students living outside the United States), their location will be considered the State of Illinois.  The student location designation will remain in effect unless and until a student changes the U.S. State or territory listed in the student’s permanent address using UIC’s online Student Self-Service portal. Once a student enters a new U.S. State or territory, the university will consider that date of entry as the effective date of a student’s revised location for the purposes of this policy. All other university policies that determine Illinois residency for the purpose of tuition assessment will not be superseded by this policy.

Reason for Policy: This policy is required to assure compliance with the U.S. Code of Federal Regulations, 34 CFR § 668.43 as amended, particularly paragraph (c), Institutional Information – Individual Disclosures for all programs leading to professional licensure or certification to prospective students if the institution makes a determination that the program does not meet State educational requirements or the institution has not made a determination where the student is located before enrolling in the program (before a financial transaction occurs.)  The institution must provide an individual disclosure to enrolled students if the institution determines that the curriculum no longer meets educational requirements where the student is located; the disclosure must occur within 14 days of the institution making that determination.

Further, the federal regulations require that each institution has a policy that defines student location for purposes of complying with the disclosure requirements.

Minority Impact Statement: This policy has no discriminatory impact on minorities and is intended to address federal government consumer protection requirements of with 34 CFR § 668.43.  When requested, and subject to applicable privacy laws, UIC will make the determination regarding a student’s location, together with any supporting documentation, available to the Secretary of Education.

Who Should Read the Policy: All academic administrators, registrar’s office and student recruitment administrative staff.

Definitions:

• Current students: Students who are currently enrolled in a University of Illinois Chicago educational program.
• Student location: This is defined as the State where the student resides using the permanent home address in the Banner Student Administration system; for prospective students this is the State they live in at the time entered into the Slate customer management system. For students whose permanent address does not include a U.S. State or territory (e.g., students living outside the United States), their location shall be considered the State of Illinois.  Location designations shall remain in effect unless and until a student changes the U.S. State or territory listed in their permanent address using the online Student Self-Service tool. Once a student enters a new U.S. State or territory, the university will consider the new U.S. State or territory as the student’s location for the purposes of this policy.
• Professional licensure program: A degree program that can lead to professional licensure or certification to ensure a professional meets certain industry requirements in terms of knowledge, experience, and currency. It is a way to acknowledge the expertise of a professional and to recognize his/her abilities in a particular field.
• Prospective students: Students who have applied for admission to a University of Illinois at Chicago educational program but who have not yet enrolled.
• Students: Students include current students and prospective students.
• State: A State of the Union, American Samoa, the Commonwealth of Puerto  Rico, the District of Columbia, Guam, the Virgin Islands, the Commonwealth of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of Micronesia, and the Republic of Palau. The latter three are also known as the Freely Associated States.

Procedures: TBA

Professional Licensure Disclosure by State Website

Related Laws, Regulations, Statutes, and Policies:

• 34 CFR § 668.43. Amendment published November 1, 2019, in 84 FR 58932.