Expert urges Illinois community colleges to update policies after new Title IV licensure certification takes effect

Chris Moll, a compliance consultant with Higher Education Licensure Pros, told Illinois community college staff during a webinar that institutions must act now to meet a new Program Participation Agreement term tied to professional and occupational licensure. The change, effective July 1, requires colleges participating in the federal Title IV student-aid program to certify that their licensure programs meet the educational requirements where the institution is located and where distance-education students are located at the time of initial enrollment.

Moll said institutions have three main responsibilities under the Title IV regulation and State Authorization Reciprocity Agreement (SARA): to understand how programs align with state licensure requirements; to certify that programs meet those educational requirements (the new PPA term); and to communicate licensure information both publicly and directly to students. "While I am an attorney, I am not your attorney," Moll said, cautioning that his remarks were informational, not legal advice.

Why it matters: Title IV compliance affects a college’s eligibility to offer federal financial aid, and licensure issues have increasingly appeared in borrower-defense-to-repayment claims, Moll said. He warned that enforcement actions for Title IV noncompliance can carry similar consequences to other Title IV…