June 15, 2020
On November 1, 2019, the U.S. Department of Education published a final rule regarding state authorization. The new rule is effective July 1, 2020. This Alert highlights required changes for state authorization and consumer disclosures, some of which apply to institutions offering on-ground programs. Key changes include: modification of Title IV state authorization requirements; a new definition regarding student location for state authorization purposes; new consumer disclosure requirements for programs that prepare students for professional licensure; and significant new and amended consumer disclosure requirements.
Institutions should carefully review the changes made by the new rule and prepare to amend their consumer disclosures to comply with the new requirements by July 1, 2020. It is particularly important that institutions develop policies that adhere to the timing and distribution requirements for the consumer disclosure requirements for programs leading to professional licensure or certification.