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Distance Education and Professional Licensing

DEAC is pleased to welcome guest blogger, Sharyl Thompson, CEOsharyl of Higher Education Regulatory Consulting to offer her insights on the complexities of distance education programs and professional licensing.

Contrary to many predictions 15 to 20 years ago, distance education has not diminished or faded away. A recent report published by WCET (WCET Distance Education Report) shows the number of online enrollments has risen from 1.6 million in 2002 to 5.8 million in 2014. With the increase in distance education opportunities has come an increase in regulatory oversight – federal, state, and accreditors.

Although state authorization regulations have been in place for many years, many institutions were unaware of them until 2010 when the U.S. Department of Education proposed new rules under the Higher Education Act. And although the federal oversight of distance education was set aside by a federal court decision, institutions all over the country learned they must take measures to be in compliance with the authorization regulations of each state. Far too many institutions are still not addressing this important issue. Furthermore, institutions that offer programs that lead to a professional license are coming under greater scrutiny.

As state higher education regulators became more aware that institutions were offering licensure-track programs through distance education, they began, in the interest of consumer protection, to pay closer attention to whether or not such programs offered to students in their states met the professional licensure requirements in their state. From the institutional perspective, many believe that, as long as they know their licensure-track programs meet the professional licensure requirements in the state of their main campus or headquarters, that would be sufficient. This is not always the case, especially for distance education programs.

With distance education in the mix, it is vitally important that institutions be aware of where their licensure-track programs do not meet professional licensure requirements and disclose that information to the general public.

At the very least, institutions need to know where their students intend to practice the licensed profession for which they are studying. Why? Here’s an example: if I am a student taking courses in Minnesota from an institution located in Florida, I wouldn’t want to go through the entire program only to find out that I can only get licensed in Florida when I have no intention of practicing my profession there. Not only would I have spent thousands of dollars, I also would have spent thousands of hours – time that can never be regained.

A second responsibility for institutions is that, when they know (because they’ve done the research – or hired to have it done) that a licensure track program they are offering does not meet the professional licensing requirements in another state, they are responsible to disclose that information to the general public. The disclosure responsibility starts with ethics—doing the right thing. But it is more than that. Disclosure requirements are mandated in some state regulations and are included in the misrepresentation rules of the U.S. Department of Education ( So, not disclosing is against the law. The State Authorization Reciprocity Agreement (SARA) also has disclosure requirements.

Institutions should act now and not wait. Institutions have an important obligation to inform students of whether or not the programs they are taking meet the professional licensure requirements in the state in which they intend to practice