UNC Charlotte Academic Procedure: Programs for Licensed Professions

i. Executive Summary

Some–though not all–programs that prepare students for employment in licensed professions face special compliance requirements from the federal government as well as other agreements in which the University participates (e.g., State Authorization Reciprocity Agreements [SARA]).  The University will use the procedures herein to 

  • Determine the programs to which these special conditions apply (hereafter referred to as “Professional Licensure Programs”) and
  • Outline the compliance actions each Professional Licensure Program must take.

ii. Procedure Statement

Requirements of Professional Licensure Programs

Eligibility to Enroll

In order to comply with 34 CFR §668.14(b)(32), beginning July 1, 2024, Programs designated as Professional Licensure Programs under this policy/procedure may only enroll students from states where the program “satisfies the applicable educational requirements for professional licensure or certification requirements in the State so that a student who enrolls in the program, and seeks employment in that State after completing the program, qualifies to take any licensure or certification exam that is needed for the student to practice or find employment in an occupation that the program prepares students to enter.”  If a program does not meet the educational requirements for licensure or the program has been unable to determine whether it meets those requirements in a particular state, students from that state cannot be enrolled.

The University will use a student’s Future Professional Licensure Location (PL) address type (shortened to “Future Prof Licensure Loc” in Banner due to field length limitations) as determined and defined by the Student Learning & Professional Licensure Location Procedure to determine the state that each student is from for the purposes of this procedure.  If a student’s Future Prof Licensure Loc (PL) address is set to XX and the prospect is not an international student (i.e., the student’s local/mailing [MA] or permanent [PR] address is not with the United States), the University should not attempt to determine the student’s eligibility to enroll in a Professional Licensure Program until the student’s PL address has been corrected to an actual U.S. state, district, or territory. 

Disclosures

Public

In order to comply with 34 CFR §668.43(a)(5)(v), UNC Charlotte will publish for each of its Professional Licensure Programs 

  • a list of the States in which the Program “meets the educational requirements for” licensure and
  • a list of the States in which the Program “does not meet” the educational requirements for licensure. 

While individual Professional Licensure Programs are encouraged to include such information in Program-specific websites and portions of the catalog, the University will consolidate this information for all Professional Licensure Programs on a single website maintained by the Out-of-State Academic Activities Coordinating Council (OoSAACC).

Direct/Personalized

In order to comply with 34 CFR §668.43(c), UNC Charlotte must make personalized, direct email disclosures about a Professional Licensure Program in the following situations: 

Email goes to:1. Prospective Student2. Currently Enrolled Student
When:Prior to student’s Enrollment in the ProgramWithin 14 days of making the determination
If:The Program does not meet the educational requirements for licensure in the student’s State

OR

The institution has not made a determination regarding whether the Program meets the educational requirements for licensure in the student’s State		The Program does not meet educational requirements for licensure in the student’s state
What the email must include:Notification that <PROGRAM NAME> does not meet the educational requirements for licensure in <STUDENT’S STATE>

OR

Notification that the institution has not made a determination regarding whether<PROGRAM NAME> meets the educational requirements for licensure in <STUDENT’S STATE>		Notification that <PROGRAM NAME> does not meet the educational requirements for licensure in <STUDENT’S STATE>

As long as admission processes in Slate continue to determine and communicate a person’s eligibility to enroll in a Professional Licensure Program long before the person becomes a “prospective student” by the University’s definition (see below),  there will be no need to set up a separate, automated process to send the direct/personalized disclosures described in column 1 above.

However, for the situation described in column 2, a nightly process that (1) identifies when either (a) a student’s PL address has changed or (b) data contained in the Professional Licensure Datastore has changed such that the student’s Program no longer satisfies the educational prerequisites for licensure in the student’s State and (2) discloses this fact to the student via email is required.  This personalized email may also include such additional relevant information as 

  • How the student’s current Future Professional Licensure Location (PL address) was determined and the part it played in deciding the student’s eligibility to enroll and/or be licensed;
  • What the Attestation process is along with when and how to use it;
  • Available advising resources;
  • Options to consider; 
  • Contact information for licensing boards; and
  • Whether a student who has already begun taking classes in the program may continue in and finish the program.

The responsibility for the creation and maintenance of this emailing system falls to the Out-of-State Academic Activities Coordinating Council (OoSAACC). 

New Program Development and/or Revision

All programs proposed or revised after July 1, 2024, should, as part of the regular program approval process, indicate whether the new/revised program will meet the definition of a Professional Licensure Program.  Indication in the affirmative generates an OoSAACC step in the Modern Campus Curriculum (previously known as Curriculog) program proposal. During this step OoSAACC can collect necessary information from the originating unit.  Professional Licensure Programs should be prepared to document the following as part of the process:

  • List of the States in which the new/revised Program “meets the educational requirements for” licensure, 
  • List of the States in which the Program “does not meet” the educational requirements for licensure, and
  • List of all the possible entry processes by which students may enroll in the program (e.g., Licensure Program Admit – Undergraduate, Licensure Program Admit – Graduate, Upper Division Program Admit, Major Change Program Admit, Minor Change Program Admit, Licensure Program Readmit).

Procedure for Identifying Professional Licensure Programs

Prior to July 1, 2024, and then periodically thereafter, the University will use the following criteria to review all offered Programs to determine whether they are Professional Licensure Programs.  Additionally, whenever a new degree, major, concentration, or minor is added or an existing degree, major, concentration, or minor makes a change, the Program should determine or reaffirm its determination whether it is a Professional Licensure Program.  

Any Program that answers “yes” to either of the following questions is a Professional Licensure Program: 

  • Is the program described in any official or unofficial communication or document (e.g., website, catalog, Curriculog submission, letter to SACSCOC or the UNC System Office, individual’s email, personal phone call, marketing flier, advertising copy) as designed or able to meet the educational requirements for licensure or certification in a given field?
  • Is a person employed in the occupation for which the program prepares students required by any U.S. state, district, or territory to hold a state-issued license or other certification in order to practice or find employment in that occupation?

Programs designated as Professional Licensure Programs are subject to the requirements of 

Procedure for Determining the Status of a Professional Licensure Program in Each State

Prior to July 1, 2024, and then periodically thereafter, each Professional Licensure Program must determine for each U.S. state, district, and territory whether it “satisfies the applicable educational requirements for professional licensure or certification requirements in the State so that a student who enrolls in the program, and seeks employment in that State after completing the program, qualifies to take any licensure or certification exam that is needed for the student to practice or find employment in an occupation that the program prepares students to enter” (34 CFR §668.14(b)(32)(ii)).

This per-program-per-state determination should be made by an expert who is familiar with the program (curriculum requirements, topics covered, etc.) and capable of accessing and interpreting each state’s licensure requirements in order to compare those requirements to the program’s characteristics.  The expert may deem a program as satisfying the educational requirements in a state if any of the following are true:

  • The program actually fulfills all of the criteria established by the state;
  • The student is able to achieve full or provisional licensure in the state through licensure reciprocity; OR
  • The program could not make a determination based on information available from the licensing board but is nonetheless able to document that graduates from the state have “all met the educational requirements for licensure or certification” in the state.

For each program-state combination, the expert should record the determination, document any reasoning or resources required to make that determination, and retain those resources.

This determination information will drive decisions about students’ eligibility to enroll and disclosures made to individuals as well as the general public.

Records Location and Maintenance

The definitive list of Charlotte’s Professional Licensure Programs and their dispositions in each State are stored in the Professional Licensure Datastore.  The Out-of-State Academic Activities Coordinating Council (OoSAACC) will oversee the maintenance of this list and set standards for keeping it up to date.   Individuals, offices, and/or systems requiring read-only access to the Datastore or needing to update its contents should contact their college’s Representative on OoSAACC or the State Authorization Manager/SARA Liaison.

iII. Definitions

  • Enrolled – “Student who has completed the registration requirements (except for the payment of tuition and fees) at the institution that he or she is attending” (34 CFR 668.2).
  • Program – Any Title IV-eligible course of study offered by the University.  Individual programs are differentiated from one another by a unique combination of degree, major,and (if applicable) concentration names. For example, for the purposes of this procedure, the Master of Education in Curriculum and Instruction with a concentration in Middle Grades Mathematics would be considered a program discreet from the Master of Education in Curriculum and Instruction with a concentration in Middle Grades Science; and each would be designated as a Professional Licensure Program.  For the purposes of this procedure, “program” can also refer to a declared minor.
  • Professional Licensure Datastore – Data file maintained by OoSAACC that lists all of the Programs that UNC Charlotte considers to be Professional Licensure Programs as well as a determination for each Program/State combination as to whether the Program satisfies the educational prerequisites for licensure in that State.
  • Professional Licensure Program – Any program that (a) claims to prepare students for licensure/certification OR (b) prepares students for an occupation that at least one U.S. state, district, or territory requires a state-issued license or certification in order to practice or seek employment in the field.
  • Prospective Student – A potential future student whose contact information (e.g., mailing address, phone number, email address) is recorded in the enterprise student information system (SIS; i.e., Banner) after receiving it from the admissions information system (i.e., Slate).  Admissions systems do not usually push this information to the SIS until an application is complete or nearly complete.  Prior to this push, most University systems and offices are unaware of this person, having no information with which to make contact. 
  • State – A state, district, or territory of the United States.

iV. Contacts

  • Authority: Office of the Provost and Vice Chancellor for Academic Affairs
  • Responsible Office: Office of the Provost and Vice Chancellor for Academic Affairs
  • Additional Contact(s): Out-of-State Academic Activity Coordinating Council (OoSAACC), School of Professional Studies

V. History

  • Established:  July 1, 2024

Vi. Related Policies, Procedures And Resources

1Based on Department comments on p. 398 of the unofficial version of the final regulations released on October 31, 2023.
2Based on and quoting Department comments on p. 386 of the unofficial version of the final regulations released on October 31, 2023.