Just wanted to check in and say hello! I think I’ve drafted a half dozen emails over the last few months, but kept getting pulled away to do campus/academic Covid planning meetings and preparations.  I hope you’re all faring well and that we’ve gotten through the worst of it… Boulder is doing what looks those in the restaurant world call a “soft open” for Fall.  We’re going to try to run things as close to normal but with a longer scheduling period (courses can run between the hours of 8am-9pm), smaller classes, bigger gaps between classes, some cohorts, more online and synchronous video options for courses etc. etc.  Honestly my biggest sigh of relief was when the ABA moved to allow for up to 1/3 of a legal education to be delivered via distance education.  We’re still awaiting their final vote, but it sailed through earlier committees w/o much discussion. 
 
July 1st is quickly approaching and with it the new regulations on professional licensure programs and notifications.  I hope everything is moving along well as you prepare for this.  As a reminder, failure to comply puts your University in danger of losing access to federal financial aid (Title IV).  How is your research coming on the various professional licensure programs and the applicability of education your Universities are offering?  I know I’ve found that the PhD in Psychology will likely not allow for students at CU Boulder to sit for the licensure exam in most states.  Looks like we don’t offer enough hours in the way of internships.  Don’t forget that NC-SARA, in an effort to continue helping the higher education community has branched out in to assisting us with our professional licensure needs – namely by gathering a directory of the most common professional licensure fields and their state agencies. This is a great head start on getting the information required for our programs and notifications as it gives you the contact information and name of all of the applicable agencies in these fields. 
 
There was an interesting conversation on the WCET/SAN listserv about one of the aspects of gathering and disseminating information.  In a conversation about some of the language in disclosures, I had indicated that for the Teaching Degrees at CU Boulder we were saying that we don’t meet any other states’ requirements for licensure when a colleague at Truman State indicated that he had thought that intent of the new regulations meant that if we admit students from other states we should also tell them why/how a program may not meet their state’s licensure requirements.  Deputy General Counsel from the University of Phoenix chimed in then noting that “If students from other jurisdictions are able to enroll and you don't restrict that, you must ensure your program meets the licensure requirements in their state, tell them about it, or tell them that it doesn't meet the requirements.” 
 
And while I have a great respect for the University of Phoenix when it comes to state authorization – remember, they have been dealing and working with all of this for much much longer than the rest of higher education – and I agree with the Deputy Counsel and with the gentleman from Truman, I do so with a caveat.
 
I agree that the intent of the regulation is for institutions to provide students with enough information that they can make an informed decision about their education. That being said, nowhere in the regulatory language does it say we're required to disclose to the students the specific state educational requirements we're not meeting, only that we disclose to them that we have either made the determination that our education does/doesn't meet the requirements in that state or we don't know if we meet the requirements in that state.   I agree that doesn't mean you shouldn't/don't have to share the information as to how you came to that determination if you wish to.  In fact, in regard to marketing, being able to make specific disclosures (and thus notifications) about how you don't/can't meet educational requirements in a particular State would likely put you at an advantage.  
 
However, I think though that we need to take the mission of the institution and the intended audience of the program in to consideration.  The example of UoP's teacher ed programs is great.  But CU Boulder's teacher ed programs are not offered in a distance modality, and our students rarely, if ever, leave the state for student teaching.  We're not aiming for or recruiting students outside of CO,  thus stating we don't meet requirements for other states is the most prudent for this program.  Does that logic carry to our other professional licensure programs?  Depends on the program, the intended audience, the modality, etc.
 
I read back through the section of the Federal Register (vol. 84, no. 212) that discusses 668.43 (pgs. 58884-58888) and the Department notes that they require "institutions to only advertise true and factual statements about their programs, " and that the "Department expects that institutions will accurately and truthfully provide that information on the required disclosure."  For this particular program (teaching degrees), and this particular disclosure, we are adhering to that intent (p.58886).  
 
I hope you’re all doing well and getting to get things somewhat back to normal or have started a new normal that agrees with you!!
 
Erika