Professional Licensure Disclosures

PURPOSE:

This policy helps to ensure the ICOM’s compliance with federal regulations (34 CFR 668.43) and its obligations as a SARA-participating institution regarding public and direct disclosure requirements related to Professional Licensure Programs.

SCOPE:

This policy applies to academic administration, recruitment, and admissions personnel that administer

Professional Licensure Programs, regardless of modality or geographic location.

DEFINITIONS:

Professional Licensure Program: A graduate degree program intended to (or advertised to) satisfy educational prerequisites for a State-issued professional license, certification, or other credential offered by a third party that is required for employment in an occupation.

Professional Licensure Disclosure Statements: announcements made by Idaho’s College of Osteopathic Medicine (ICOM) that provide information to the general public (e.g., public disclosures) or by directly notifying students (e.g., direct disclosures) about whether programs leading to professional licensure or certification meet educational requirements for licensure or certification in a particular State.

SARA: The State Authorization Reciprocity Agreement, commonly known as SARA, is an agreement among member states that authorizes an institution located and legally authorized in a State covered by the agreement to provide out-of-state activities to students located in other States covered by the agreement. Institutions that participate in SARA agree to abide by a set of quality expectations, reporting requirements, and consumer protection practices that are promulgated by the National Council of State Authorization Agreements (NC-SARA) and upon which Member States have agreed. SARA does not affect the applicability of general-purpose State laws such as business registries, general-purpose consumer protection laws, worker's compensation laws, criminal statutes, and the like. SARA does not affect State professional licensing requirements. Additional authorization may be required in SARA-member States if the institution conducts certain activities not covered by SARA Rules.

SARA Rule: A written statement promulgated by NC-SARA that is of general applicability; implements, interprets, or prescribes a policy of SARA or provides an organizational, procedural, or other requirement of NC-SARA, including policies contained in the SARA Manual.

State: A State of the Union, American Samoa, the Commonwealth of Puerto Rico, the District of Columbia, Guam, the Virgin Islands, the Commonwealth of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of Micronesia, and the Republic of Palau.

Student Location: For purposes of this policy, the student location is defined as the State in which a student is currently living (e.g., permanent/home address) at the time of initial enrollment and upon formal receipt of information from the student that their location has changed to another State while engaged in ICOM educational activities. For prospective students, student location is the State of the prospective student'slocation at the time the individual has applied for admission, intends to enroll, and is then entered into the College’s recruitment or student information system portal.

POLICY:

The U.S. Code of Federal Regulations, specifically 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c) requires ICOM to provide public and direct disclosures to prospective and enrolled students regarding its Professional Licensure Program for the Doctor of Osteopathic Medicine Degree Program.

Public Disclosures:

ICOM makes readily available to enrolled and prospective students’ information on its academic program. ICOM provides public disclosure of information regarding the Professional Licensure Program on its Accreditation website in the Professional Licensure Table, which indicates whether completion of the Professional Licensure Program would be sufficient to meet educational requirements for licensure in a State for that occupation and includes:

• A list of all States for which the institution has determined that its curriculum meets the State educational requirements for licensure or certification.
• A list of all States for which the institution has determined that its curriculum does not meet the State educational requirements for licensure or certification; and
• A list of all States for which the institution has not made a determination that its curriculum meets the State educational requirements for licensure or certification.

Accordingly, academic department chairs administering such programs and who serve as content experts will annually investigate the rules of professional licensing boards to determine if their program meets, does not meet, or they are not able to make a determination regarding state requirements for licensure or certification. These public disclosures will indicate the States where the College has determined through reasonable, good faith effort, that the Professional Licensure Program does or does not meet the applicable professional licensure education requirement, or the College has not yet made a determination.

These public disclosures are in accordance with the federal regulatory requirements set forth in 34 CFR 668.43(a)(5)(v) and SARA Rules.

Direct Disclosures:

Prospective Students: A direct disclosure is required by 34 CFR 668.43(c) by ICOM to the prospective

undergraduate or graduate students, in writing, if:

1. The curriculum of the intended Professional Licensure Program does not meet State educational requirements for licensure or certification in the State in which the prospective student is located; or
2. ICOM has not made a determination regarding whether the program's curriculum meets State educational requirements for licensure or certification.

The notice must be provided, in writing (email or letter), prior to the student's enrollment in the program (e.g., tuition deposit or other financial commitment).

Enrolled Students: A direct disclosure is required under this regulation if ICOM makes a later determination that the curriculum of a Professional Licensure Program does not meet the State educational requirements for licensure or certification in a State in which a student who is currently enrolled in such program is located. The notice must be made to the student, in writing (email or letter), within 14 calendar days of making such determination.

This provision would likely happen most often when a program loses its approval in a State or the student relocates. Changes to student location will be upon formal receipt of information from the student that the student has changed to another State. (Refer to Student Location Policy.)

Student Location:

ICOM makes a determination regarding the State in which a student is located in accordance with its policies and procedures, which are applied consistently to all students. For purposes of this policy, student location is determined based on ICOM’s Student Location Policy.

ICOM will, upon request, provide the U.S. Secretary of Education with written documentation of its determination of a student's location, including the basis for such determination.

Roles and Responsibilities:

A. Director of Compliance:

1. Ensures that the required public Professional Licensure Disclosure Statements are published and made available via the ICOM’s Accreditation Information website;
2. Maintains the ICOM’s Professional Licensure Table in response to updates and ensures this Table is made available via ICOM’s Accreditation Information website.
3. Notifies the Office of the Registrar when changes are made to ICOM’s Professional Licensure Table

B. Associate Dean for Student Services in collaboration with the Office of the Registrar:

1. Provides the required direct Professional Licensure Disclosure Statement to a prospective or newly enrolled undergraduate or graduate student when:
   1. ICOM has not made a determination whether the Professional Licensure Program of interest meets educational requirements for licensure or certification in the State where the prospective student is located.
   2. ICOM determines the Professional Licensure Program of interest does not meet educational requirements for licensure or certification in the State where the prospective student is located.
   3. Direct Professional Licensure Disclosure Statements must take place, in writing (email or letter), prior to the student's financial commitment (e.g., tuition deposit) to the College.
2. Maintains records of direct Professional Licensure Disclosure notifications.

C. The Office of the Registrar:

1. Holds primary responsibility for developing and consistently applying internal administrative procedures to determine where students are located.
2. Determines and tracks student location each term or semester and reports, in a timely fashion, to academic department chairs and Vice President for Enrollment Management the necessary data to provide the Professional Licensure Disclosure Statements as set forth in this policy;
3. Provides the required direct Professional Licensure Disclosure Statements to enrolled students, in writing, if the institution later determines that their Professional Licensure Program's curriculum no longer meets the applicable educational requirements for licensure or certification in the State where the student is located. This provision would likely happen most often when a program loses its approval in a State or the student relocates. Changes to student location will be upon formal receipt of information from the student that the student has changed to another State. (Refer to Student Location Policy.) This disclosure must occur in writing (email or letter) within 14 days of the College making that determination in accordance with federal regulation 34 CFR 668.43.
4. Maintains records of direct Professional Licensure Disclosure notifications.

D. Dean/Chief Academic Officer:

1. Serves as the policy officer and is primarily responsible for ensuring the College's overall compliance with this policy.

PRIMARY POLICY OWNER:

Director of Compliance

SUPPORTING DOCUMENTS:

APPROVAL:

Effective: 8/1/23

Last Reviewed: 1/25/24

Review Requirement: 5 Years