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Webinar: institutions report steep workload increases under Title IV licensure rules, many restrict enrollment
Summary
A Midwestern Higher Education Compact webinar summarized a spring 2025 survey of 228 institutions showing 86% reported moderate or significant increases in licensure-compliance workload after the July 2024 Title IV certification-procedures rules; about 32% of respondents restrict enrollment in some states for certain programs.
Jonathan McNichols, manager of policy and stakeholder engagement at the Midwestern Higher Education Compact, opened the webinar and introduced a panel of licensure-compliance experts who reviewed survey results from spring 2025.
Panelists said the Department of Educations July 2024 certification-procedures changes require affirmative, state-by-state determinations that can prevent institutions from enrolling a student if the institution cannot determine a program meets that states educational requirements. "If an institution cannot determine whether the program meets the educational requirements, institutions generally cannot enroll the student," a panelist said, describing the regulatory change and its enrollment implications.
The panel reported that 86% of survey respondents described a moderate or significant increase in licensure-compliance workload; roughly 48% labeled that increase as significant. Respondents estimated added compliance time varied widely; 72% reported adding 1—0 hours weekly, with 4— hours cited most often. The survey captured 228 responses and 16 in-depth interviews representing two- and four-year public and private institutions.
Panelists identified the five most time-consuming tasks: state law and licensing-board research (cited by 90% of respondents), student disclosures and communications (85%), internal coordination and training (79%), ongoing monitoring of state and federal requirements (63%), and data reporting or documentation (51%). Only about 6% said their primary method for determining state alignment was direct confirmation from licensing boards; 82% relied on internal interpretation or a mix of interpretation and informal external references.
To manage operational risk, about 32% of respondent institutions said they had restricted enrollment in particular states or for particular programs; nursing, teacher education and mental-health programs were the most frequently cited program areas. Panelists identified California, New York, Texas, Washington, Colorado, Georgia and Tennessee as states that regularly present complex or costly compliance challenges.
The panel emphasized that the burden and institutional response vary by institution size, number of licensure programs and internal capacity: only about 22% hired additional staff, 43% use student self-attestations to permit enrollment under exceptions, and only about 6% have a fully automated disclosure process. Many institutions still rely on spreadsheets and manual workflows.
The webinar closed with a reminder that the presentation and recording will be posted to the Compacts website and an encouragement to use the survey data to support resource requests and institutional planning.
