Over the past 6 months, HELP has discovered trends as to how institutions are meeting the federal and NC-SARA professional licensure public disclosure requirements. Spoiler alert: for the most part, they aren’t!
New federal regulations (34 CFR 668.43(a)(5)(v) & 34 CFR 668.43(c)) added to the Higher Education Act (HEA), effective July 1, 2020, require institutions of higher education to:
The National Council for State Authorization Reciprocity Agreements (NC-SARA) Board aligned their policy with the new HEA federal disclosure requirements and added the expectation that its members make reasonable efforts to determine whether their curricula meet state and territory educational requirements. See Sara Manual section 5.2 - Programs Leading to Professional Licensure - Version 20.2 revised June 15, 2020.
Changes for approval requirements to maintain GI Bill participation in Public Law 116-315 , Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020, signed January 5, 2021. Section 1018: Requirements for educational institutions participating in the educational assistance programs of the Department of Veterans Affairs, effective June 15, 2021, and will apply to Institutions of Higher Learning and Non-College Degree institutions beginning August 1, 2021. These changes are related to the requirements of the Principles of Excellence with which many of you are already familiar. Section 1018(f)(1)(A)(ix) requires individualized disclosure of any conditions or additional requirements, including training, experience, or examinations, required to obtain the license. certification, or approval for which the course of education is designed to provide preparation (see Public Law 116-315 ).
Most institutions are not in full compliance
Colleges and Universities are aware of the federal regulations and NC-SARA policy requiring them to disclose how their programs (leading to a certificate or professional license) meet or do not meet licensure requirements in all U.S. states and territories. Yet to a large extent they are not meeting them.
Based on an informal audit of social work programs offered online and distance education that are approved or in candidacy by the Council on Social Work Education (CSWE):
Some examples of disclosure statements we found that do not meet the federal regulation:
* Licensure requirements vary by state. Students are responsible for understanding the requirements for social work licensure in their resident state. Applicants seeking licensure are encouraged to review all applicable eligibility requirements related to the respective occupational license per the Texas occupations code HB 1508.
*While Council on Social Work Education (CSWE) accreditation is a requirement for social work licensure in all states, it is not the only educational requirement in all states. Twenty states require specific coursework or training requirements in addition to completion of a CSWE accredited degree to qualify for a license.
The table below provides a state by state breakdown of comparable licenses, including a determination of eligibility for licensure. This information provided is designed as a baseline determination of whether the program meets individual state specific requirements. Licensure requirements, the type of license to apply for, and appropriate pathway to pursue are subject to change and may differ based on individual student backgrounds, including coursework taken outside the scope of the program. Students should do their own due diligence and determine the appropriate pathway and license type for themselves.
Colleges and universities are in a tough spot!
Even pre-pandemic, many lack people power. Institutions have to decide who is going to complete the work - legal research, curriculum comparison, disclosure language, and communicating with state licensure boards - required to understand and communicate.
Consider:
*Costs (monetary and opportunity)
*Time to complete
*Level of expertise
Review our Blog, Tips and Guidelines for Licensure Research” posted on February 22nd and look for our next Blog on Research Tips Part 2”