WCET-SAN is turning 12 this year - almost angsty teens! - and there is reportedly some new stuff coming our way (like some examples on best practices and a checklist on how to get started with professional licensure programs/disclosures by myself and some colleagues in the SAN-SIT on Professional Licensure, as well as other things) and we'll be renewing our membership which gives us access to varieties of information, news, and support (not to mention the WCET-MIX listserv where we can get advice from, and connect with, colleagues across the country and in a variety of sectors). If you're not familiar with all that WCET-SAN has to offer, take some time to check them out and let me know if you have any questions.

So. . . what can we be doing right now while we wait for the Department to drop some officially proposed regulations on us (likely in May and on a Friday so we can spend all weekend reading them)? Well, speaking of WCET, they recommend that we take some time to do some, or all, of the following:

• For Professional Licensure: Start Assessing Your Institution’s Professional Licensure Status in Each State in Which You Intend to Serve Students. Remember, the expectation is that you can "ensure" that your program meets the educational requirements of each state in which you plan to disburse Title IV aid. There are some parts of the rules (especially around student notifications) for which we are at a loss as to what they will propose, but should the language be proposed as many of us think, we should be ready to report on what impact these rules will have on your institution, and for each program (and future potential students). Should we need evidence for a System (or wider) comment to the Department, this information will be integral.
  • Determine your target states. Each program that leads to licensure probably primarily targets a set number of states that contain the bulk of your enrollments. Note that the word “licensure” might be “ceritfication,” approval,” “authorized,” or “permitted” for the profession in question. All of those terms are included under the concept of “licensure” for this purpose.
  • Ask the hard question. Ask the question: “do you have proof that you met the educational requirements for licensure in that profession in that state?” Assume that you have a financial aid official sitting across from you asking that question. We have heard of program personnel waving their hands in the air and saying, “we don’t have to do it.” Prove it.
  • Conduct scenario analyses. Given the answers to the hard question, what are the best and worst-case scenarios?
• For State Authorization Reciprocity: The (perceived) intent of the rule is to limit reciprocity only to the act of applying for institutional authorization in a state and any associated fees. This one is harder to estimate because it will be dependent on a variety of independent actions (by states, reciprocity agreements) in response to this regulation. Meanwhile, on your campus, look in to the following:
  • What are your target states for delivering education (i.e. beyond Colorado)? Are there target populations by program or by state? You will want to talk to the folks in admissions and see how this might affect their work and recruitment strategies.
  • Create a list of the states where you serve the most students (i.e. where are your distance and correspondence students located - b/c yes this will effect Coursera offerings despite the lack of federal aid being used there).
  • Be prepared to do some scenario analyses. For the states that you target, what additional costs might you incur (look to pre- SARA requirements - what did a state require we do, did we have to have some specifics in a tuition refund policy, did we have to contribute to the state's tuition recovery fund)? How would you recover those costs (i.e. would these potential costs be passed on to the student in the form of higher tuition or other fee)?

I have already taken a look at two or so programs on the Boulder campus and how we have been advertising or describing them: Geology (my favorite!) and the Bachelors of Environmental Design (specifically the Architecture and Landscape Architecture concentrations). For the Bachelor's and Master's in Geology we determined that as CO has no licensure for professional geologists and the programs were originally designed as academic - and not professional - programs, and as they are not offered in a distance modality, that we would expressly declare that as such and indicate that the programs have never been designed to meet licensure requirements in any state. And while we will continue to list the various state agencies that may over see the licensing of professional geologists, we are firmly placing this program outside of the professional licensure sphere.

As for Environmental Design and its concentrations, this program is actually a "preprofessional" program. That is, they're preparing students for future (graduate) education in the specific fields of Architecture and Landscape Architecture, but not giving the students the education they need to be professionals in the field. We reviewed a webpage or two and some text in the catalog and made some general tweaks over the last year or so to make that more clear which is great. In a recent conversation on the possibility of creating an articulation agreement with another institution, we reaffirmed this designation as a preprofessional program and will be removing the B-ENVD from our list of general and direct disclosures in the coming weeks. Under current (and potential future) regulations, pre-professional programs are exempt from these disclosures.

There are other things (e.g., conversations with folks in the Accounting department in the Business School about recruitment and CPA requirements) that I've started doing as well, and more that I'm puttng on the agenda for the coming weeks (like reviewing distance enrollments by state).

And finally - don't forget - NC-SARA data reporting starts in a few weeks! If you're one of the folks responsible for that make sure you take the time to review this year's Data Reporting Webinar.

Have a great weekend everyone!
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