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NC‑SARA policy 5.2 now covers many non‑Title IV and noncredit licensure programs; institutions told to inventory offerings and tighten disclosures
Summary
A Midwestern Higher Education Compact webinar explained that NC‑SARA policy 5.2, effective July 1, 2025, extends licensure disclosure and related Title IV obligations to non‑Title IV and many noncredit programs. Presenters urged colleges to inventory programs, research state requirements, update public disclosures, and manage third‑party provider relationships.
Jonathan McNichols, manager of policy and stakeholder engagement at the Midwestern Higher Education Compact, opened a July webinar introducing NC‑SARA policy 5.2 and said resources and written answers to attendee questions would be posted after the session.
Chris Moll, an attorney and licensure compliance practitioner, told attendees the key change in SARA policy 5.2 "is applying the requirements around licensure to all non‑Title IV programs," and confirmed the policy has been in effect since "07/01/2025." He said the revision removes prior language that required institutions to use "all reasonable efforts" and to provide contact links to out‑of‑state licensing boards, and instead extends responsibility for licensure‑related disclosures and certain Title IV‑linked processes to noncredit and other non‑Title IV offerings when they are offered under the institution's SARA authorization.
Moll defined a licensure program for SARA purposes as any program "designed to lead to that state issued credential that's required for employment," and listed practical clues institutions should use: curriculum aligned with professional standards or programmatic accreditation, explicit marketing that a program prepares students for a licensing exam, reporting of exam pass rates, or expectations that graduates will seek licensure. He gave examples of in‑scope noncredit offerings such as phlebotomy, pharmacy‑technician, medical‑assistant and real‑estate broker courses, and contrasted them with programs that typically fall outside SARA (national private certifications or federal certifications like FAA credentials).
Moll walked through four compliance steps he recommends institutions take: (1) inventory all programs and offerings (including third‑party and workforce arm courses) to identify those designed or advertised for licensure; (2) research and compare curricula against the educational requirements of states where students are located; (3) update public disclosure pages so they indicate whether a program "meets" or "does not meet" state educational requirements; and (4) implement enrollment restrictions or require a written attestation when a program does not meet requirements in a student's location. He emphasized that written attestations must name one specific state or territory where the program does meet the educational requirements, and that for current students institutions must provide direct disclosures within 14 calendar days of a location change.
On practical challenges, Moll cautioned that state licensing boards rarely provide definitive out‑of‑state acceptances and that institutions should retain documentation of their research and communications to support meet/does‑not‑meet determinations. He also warned that third‑party arrangements (for example, courses offered through Ed2Go or similar vendors) are captured by the institution's SARA authorization if the offering is provided under the institution's name or revenue is shared, and thus must be included in compliance work.
Moll urged institutions to engage their academic partners, state portal entity (SPE) staff, and institution counsel while developing processes, and pointed attendees to NC‑SARA resources and an MEC research tool covering over 80 license types. He closed by reminding attendees that the webinar slides and recording will be posted and that remaining Q&A will be answered in writing.
