On November 1, 2019, the U.S. Department of Education published a final rule regarding state authorization. The regulation goes into effect on July 1, 2020 and places new disclosure requirements for professional licensure programs that apply to both online and on-ground programs.

Specifically, 34 C.F.R. § 668.43(a)(5)(v) (Institutional Information), requires institutions offering programs leading to occupational licensure (such as cosmetology, vocational nursing, etc.), to determine whether the program curriculum meets educational requirements for licensure or certification in each state. The institution must list (a) states for which the program curriculum meets educational requirements; (b) states for which the program curriculum does not meet education requirement; (c), and states for which the institution has not made a determination. Please note that the regulation applies to program curriculum,(not the ability to transfer a license to another state after the student obtains a license in the state the institution is located in.

Institutions should do the research to make affirmative or negative determinations as to whether the program curriculum meets educational requirements for licensure or certification. However, these determinations do not need to be fully completed by July 1, 2020. Until the institution is able to make the state-by-state determinations, the states that the institution does not operate in should be listed as a state for which the institution has not made a determination.