Student Location Policy for Licensure Direct Disclosures

Overview

In accordance with U.S. Department of Education licensure disclosure requirements, Geneva College records the location of prospective and current students. Geneva tracks this location to determine if licensure disclosures are needed in the following instances:

At the time a prospective student goes through the process of admission
At the time of initial enrollment in an academic program designed or advertised as leading to licensure required for employment in an occupation:
- When a student enrolls at the college for the first time
- When a student changes his/her academic program
At the time a current student formally updates his/her legal home permanent address information

Background

34 CFR 668.43(c)(3)(2) requires institutions to have a policy to determine the location of a student at the time of the student’s initial enrollment for the purpose of sending required licensure disclosures. This location should be updated upon formal receipt of new location information from the student.

Additionally, 34 CFR 668.43(c)(1) and 34 CFR 668.43(c)(2) require that institutions send appropriate licensure disclosures to prospective students and current students, respectively, according to their location as determined by the policy. Further, NC-SARA policies require institutions to annually report student enrollment according to student location information as determined for the institution’s IPEDS enrollment report. NC-SARA also requires that institutions satisfy all federal requirements for disclosures, regardless of whether the institution is a Title IV institution.

Furthermore, 34 CFR 668.43(a)(5)(v) requires institutions to provide a public disclosure for programs leading to professional licensure or certification. This public disclosure should be publicly and readily available (i.e., on the institution’s website) and should include a list of states where the curriculum does meet state educational requirements and a list of states where the curriculum does not meet state educational requirements for each educational program (regardless of modality) that is designed or advertised to meet state educational requirements for a specific professional license or certification that is required for employment in an occupation.

Definitions

Legal Home Permanent Address: the address listed as the *LHP (Legal Home Permanent) address in Geneva’s student information system (i.e., Jenzabar)

Program: an academic program designed or advertised as leading to professional licensure

State: any of the 50 states, the District of Columbia, or other U.S. jurisdiction (i.e., territories)

Determining Student Location

Prospective Students

34 CFR 668.41(a) defines a prospective student as “any student who has contacted an eligible institution requesting information concerning admissions to that institution.” The Preamble of the Department of Education 2019 Federal Rule as recorded in the Federal Register (Vol. 84, 58886) indicates that institutions send disclosures to prospective students prior to signing an enrollment agreement or making a financial commitment. Therefore, institutions need to make a location determination of each prospective student prior to enrollment or accepting a financial commitment from a student.

Geneva asks prospective students to provide their legal home permanent address information as part of their application for admission. This information is stored in the Geneva system of record (i.e., Slate and Jenzabar). The Admissions Office tracks the location information of students in programs designed or advertised to meet educational requirements for licensure once students apply to Geneva College. This process ensures that appropriate professional licensure disclosures are sent to students prior to their enrollment or making a financial commitment to the college.

For purposes of federal regulations, 34 CFR 668.43, a student applying for a Geneva College degree program is determined to be located in the state of Pennsylvania if any of the following criteria are true:

The student will be living in Geneva College campus housing. This includes admitted students with an active housing application on file for their first term of enrollment.
The student will be enrolling in a campus-based program in which on-campus coursework is required in the initial semester. (Note: Required on-campus coursework in the initial semester of enrollment excludes 1-week intensives.)
The student has a current legal home permanent address in the state of Pennsylvania at the time of application and/or when classes begin in his/her initial semester of enrollment into the program.

If NONE of the above criteria are true, the student’s location will be determined by the state or territory listed as his/her legal home permanent address on his/her application.

Current Students

The Registrar’s Office tracks address changes for students enrolled in programs identified as designed or advertised to meet professional licensure criteria. This data is stored in the Geneva system of record (i.e., Jenzabar). When a student formally updates his/her address information, the Registrar’s Office is notified via automated email. The Registrar’s Office will send updated address information to the relevant program department(s) for any student who will need to receive a professional licensure disclosure from the program department(s) due to his/her new location or new program.

For purposes of federal regulations, 34 CFR 668.43, a student enrolled in a Geneva College degree program is determined to be located in the state of Pennsylvania if any of the following criteria are true:

The student is living in Geneva College campus housing.
The student is enrolled in a campus-based program in which on-campus coursework is required in the initial semester. (Note: Required on-campus coursework in the initial semester of enrollment excludes 1-week intensives.)
The student has a current legal home permanent address in the state of Pennsylvania as recorded in the student information system.

If NONE of the above criteria are true, the student’s location will be determined by the state or territory listed as his/her legal home permanent address in the student information system.

Licensure/Certification Direct Disclosures

Criteria for Direct Disclosures

In accordance with 34 CFR 668.43, Geneva sends written direct disclosures to prospective and current students. These disclosures are sent as emailed letters.

Prospective Students

Geneva sends a professional licensure direct disclosure to prospective students who have applied to an academic program designed or advertised to meet educational requirements for a specific license/certification required for employment in an occupation if one of the following is true:

Geneva has not determined whether the student’s program of interest meets educational requirements for licensure/certification in the state/territory where the student is located.
Geneva has determined that the student’s program of interest does not meet the educational requirements for licensure/certification in the state/territory where the student is located.

Note: A student who is located in a state about which Geneva has either not yet made a determination or has made a determination that the student’s program of interest does not meet educational requirements for licensure/certification will not be admitted unless he or she completes the written attestation process.

Current Students

Geneva sends a professional licensure direct disclosure to a current student if one of the following is true:

Geneva has made a determination that the student’s program no longer meets the educational requirements for licensure/certification in the state/territory where the student is located.
The student changes his or her location, as determined by this location policy, to one in which Geneva has not determined whether the student’s program meets educational requirements for licensure/certification.
The student changes his or her location, as determined by this location policy, to one in which Geneva has determined that the student’s program does not meet the educational requirements for licensure/certification.
The student changes his or her program and is located in a non-meet state/territory for that program, as determined by the location policy.

These disclosures are sent to the student within 14 calendar days of making such determination.

Content of Direct Disclosures

The licensure/certification direct disclosures state one of the following regarding licensure/certification educational requirements: 1) Geneva has not determined whether the student’s program of interest meets educational requirements for licensure/certification in the state/territory where the student is located, or 2) Geneva has determined that the student’s program of interest does not meet the educational requirements for licensure/certification in the state/territory where the student is located.

As appropriate, Geneva will assist the student in obtaining contact information for the appropriate licensing body if Geneva has not determined whether the student’s program of interest meets educational requirements for licensure/certification in the state/territory where the student is located.

Process for Direct Disclosures

Prospective Students

The Admissions Office tracks prospective student location and, in coordination with the relevant program director(s), sends necessary disclosure communication to prospective students where direct disclosure criteria apply.

Current Students

It is the responsibility of the relevant program department(s) to ensure disclosure communication is sent to a student if he/she needs to receive any updated licensure/certification disclosure information due to his/her new location, new program, or if a new determination has been made regarding an academic program not meeting education requirements for licensing/certification in the location of the student.

Timing of Direct Disclosures

Prospective Students

The publication of the updated Federal guidelines on disclosures states, “the Department [of Education] expects that the institution will provide this disclosure before a student signs an enrollment agreement or, in the event that an institution does not provide an enrollment agreement, before the student makes a financial commitment to the institution” (Federal Register, Vol. 84, 58886). Geneva sends direct disclosures to prospective students before signing an enrollment agreement or making any financial commitment.

Current Students

34 CFR 668.43(c)(2) requires that institutions notify current students within 14 days if 1) a program designed or advertised to meet educational requirements for a license/certificate required for employment in an occupation no longer meets the licensure educational requirements for a given state or 2) a student’s location changes to a state in which Geneva’s program does not meet the licensure educational requirements or Geneva has not yet made a determination if the program meets licensure educational requirements. In accordance with the Federal guideline, Geneva sends these disclosures to students within 14 calendar days of making the above determination.

Applicability of Student Location Policy

All other college policies that determine location for the purposes of tuition pricing, grants/aid, reporting, etc. will not be superseded by this policy. In other words, this student location policy will only be used in the context of determining student location for purposes of sending direct disclosures to students interested or enrolled in programs designed or advertised as leading to professional licensure.