U.S. Department of Education Finalizes State Authorization Regulations

Map of United States with red word "update" stamped across

New federal state authorization regulations finalized November 1, 2019 impact all Ohio State units that offer online or on-campus licensure programs. The U.S. Department of Education regulations generally follow language agreed upon by a negotiated rulemaking committee in June 2019.

What does the regulation say?

Similar to previous versions of the regulation, the new regulation requires institutions to be authorized to operate in a student’s state and to provide disclosure information to students. The final regulation clarifies the authorization requirement and expands required disclosures to all licensure programs. Previously, these disclosures only applied to licensure programs offered online.


Under the new regulation, institutions must be authorized to operate in the state where a student is located in order to disburse Title IV financial aid such as grants, loans and work-study funds. The final regulation clarifies language in previous versions that required institutions to be authorized in the state where a student “resides.”

The final regulation recognizes participation in a state authorization reciprocity agreement as one way to meet authorization requirements in a state. Ohio State currently participates in the State Authorization Reciprocity Agreement (SARA). Therefore, the department’s recognition of reciprocity allows Ohio State to continue to follow SARA’s streamlined authorization processes in 49 SARA member states.

Professional Licensure Disclosures

Consistent with the proposed regulation that was released for public comment in June 2019, the final version requires institutions to disclose the following information for online and on-campus licensure programs:

  • A list of states in which the program meets educational requirements for licensure
  • A list of states in which the program does not meet educational requirements for licensure
  • A list of states in which the institution has not made a determination whether the program meets educational requirements for licensure

As students become increasingly mobile both before and after graduation, the department indicated that sharing disclosures for all licensure programs is the best way to ensure that students know whether a program will prepare them for licensure in a particular state. According to guidance published by the department, institutions can comply by posting licensure disclosure information on the institution’s website.

When does the new rule take effect?

The final regulation takes effect July 1, 2020. However, institutions may opt to implement the regulation early. Ohio State’s state authorization team is partnering with the Office of Legal Affairs and Student Financial Aid to analyze the benefits and risks of early implementation.

What’s next?

In the last few months, the state authorization team has met with licensure program contacts in each unit to create an inventory of on-campus licensure programs that may be affected by the new rule. The team is discussing compliance options with university leaders and will share a strategy and next steps with licensure program contacts soon.

Contact the state authorization team to provide input on compliance strategies or to discuss the impact these regulations will have on licensure programs in your unit.