Happy May, everyone! 

The NC-SARA data reporting period is almost here! The reporting window will be open from May 15 to June 15. For those of you responsible for the data reporting, I highly recommend reviewing this year's Data Reporting Handbook. It provides guidance on how to report data in light of the impact of COVID-19, especially regarding distinctions that need to be made for Out-of-State Learning Placements (OOSLPs) and the shift to online learning. 

WCET-SAN is offering a SAN Basics Workshop from June 23-25. It will be held virtually and synchronously (10 a.m. - 2 p.m. Mountain Time). You can read more about the workshop, what will be covered, and the expected time commitment on the SAN website.  As a system, we have a membership, and I highly recommend registering if you have the time. The system will cover the cost for two people from each campus to attend. Please let me know if you'd like to register, and we can make it happen.

Also from WCET-SAN, on May 19 (11 a.m. Mountain Time), there will be a webinar/policy session on Professional Licensure Notifications for current and prospective students. This one-hour session is free of charge but requires pre-registration. Grab an early lunch and join in for a session covering all the nuances associated with these disclosures.

In other news, here are two updates on regulations or pending regulations that may impact you:

• In a conversation with a colleague at the University of Michigan, it was noted that Genetic Counselors are beginning to see states acting on regulations to require licensure. It would be advisable to contact your faculty in that program or related programs that may be assisting students in securing positions in this field. Begin looking into this issue, especially as Colorado appears to be moving toward requiring licensure. 
• New regulatory language from the Veterans Administration (VA) has emerged regarding licensure disclosures and institutional compliance requirements (thanks for the heads-up, Jodi!). 
  • R.7105 - Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020 
  • Became Public Law No: 116-315 on January 5, 2021. Effective 6/15/21 and applies to all educational institutions as of 8/1/21. 
  • Specifically relevant to us is the requirement that, as part of our notifications, we must provide students with any conditions or additional requirements (including training, experience, or examinations) necessary to obtain the license, certification, or approval for which the course of education is designed to prepare them. 

Deep breath

While this technically applies only to students using VA funds for their education, it could have broader implications for our compliance with federal regulations and NC-SARA guidelines. Per the Department of Education, we're not required to inform students or document additional steps (e.g., post-doctoral hours, residency, years of practice, etc.) they may need to complete beyond the education we provide before sitting for licensure exams or securing employment. However, Cheryl Dowd at WCET-SAN and others are working with the VA and the State Approval Agency to seek clarification and guidance, as this goes beyond the requirements set by the Department of Education, state licensure disclosure requirements, and NC-SARA guidelines. 

After several conversations with colleagues at other universities, as well as Heather DeLange at CDHE, while none of them have an official stance on the matter, the general consensus is that for now, we should continue to collect and publish our programs’ applicability to various states' licensure exams as we have been. That being said, we should also work with our VA office to ensure they understand that those of us handling professional licensure information will provide them with what we have and explain our notification processes for current and prospective students. If this new rule takes effect on 8/1/21 as written, we will work with them to find a compliant process for their students that meets the spirit of the VA’s regulations. Lori Williams at NC-SARA has informed me that they are also looking into this issue on behalf of member states and participating institutions. I’ll share any further clarification from NC-SARA or other sources as soon as I receive it! 

Finally, a student recently asked about professional licensure and the applicability of their education and mentioned consulting a national organization for licensure requirements. Please remember not to direct students to national professional organizations when providing state licensing board contact information. While national organizations and other third parties can be helpful starting points for research, they cannot be relied upon for accurate information regarding licensure requirements. Always direct students and the public to the appropriate state agency, as they are the authority on state licensure requirements. 

Have a wonderful weekend!
Erika

Erika G. Swain
Interim Assistant Director for State Authorization
Office of Academic Affairs
University of Colorado System
e: swaine@cu.edu
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Assistant Director for Compliance and Authorization
Office of Data Analytics | Office of Institutional Research
University of Colorado Boulder
e: Erika.Swain@colorado.edu
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o: (303) 735-8184
c: (518) 637-9785