An online program can enroll a student in any state. A license is issued by one state at a time. That gap used to land on students who finished a degree and then learned it did not meet their own state's education requirement for the license they wanted. Federal student aid regulations now address it directly, and anyone enrolling online in a program that leads to licensure or certification (nursing, teaching, counseling, engineering, surveying and many more) should know what the rule requires of the school.

What the rule requires

The requirement sits in the Department of Education's program participation rules for institutions that take federal student aid. For each program eligible for that aid, the institution must determine that the program meets three conditions in every state where the institution is located and every state where its distance education or correspondence students are located when they first enroll:

  • it holds programmatic accreditation if the state or a federal agency requires it for the occupation (or pre-accreditation, where that is enough);
  • it satisfies the state's educational requirements for the license or certification, so that a graduate who seeks work in that state qualifies to sit any required licensure or certification exam;
  • it complies with the state's laws on closures, such as record keeping, teach-out plans and tuition recovery funds.

There is one more option written into the rule. A student who enrolls on or after July 1, 2024 can attest that they intend to work in a different state, and the licensure and accreditation conditions then apply to that state instead of the one where they live.

What schools must tell you

A separate disclosure rule covers programs that are designed to meet licensure or certification requirements, or that are advertised as meeting them. The school must publish a list of the states where it has determined the program does meet those requirements and the states where it does not.

It must also tell students directly. If the school has decided the program does not meet the requirements in a prospective student's state, or has made no determination for that state, it must say so in writing before the student enrolls. If it later decides a program no longer meets the requirements in a current student's state, it has 14 calendar days to notify that student. Notices can be sent by email. Each school sets its own policy for deciding which state a student is in, must apply it consistently, and must decide again when it formally learns that a student has moved.

What the rule does not do

It does not make a state board accept the degree; the board still decides each application. It covers education requirements, not experience, exams or background checks. And it applies to programs at institutions that take federal aid. For engineering in particular, many boards look for a degree from a program accredited by ABET's Engineering Accreditation Commission, and the program's status can be checked in ABET's own accredited program search alongside the school's state list.

What to check before you enroll

Find the program's professional licensure disclosure page, which most schools post under a name like state authorization or licensure disclosures, and look for your state on it. If your state is listed as not determined, ask the school in writing whether it will determine it before you enroll. If you plan to move after graduating, ask about the attestation option. Then read your state board's education requirements yourself, since the board's rule is the one that decides your application.

Licensure and renewal rules differ by state and change over time. Check the current requirements with your state licensing board before you act on them.

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