Panelists urge institutions to formalize licensure-compliance processes: committees, documentation, attestations

Panelists at the Midwestern Higher Education Compact webinar recommended operational steps institutions can take to manage the new Title IV certification-procedures obligations and the related SARA considerations.

Chris Maul, a licensure-compliance consultant, advised institutions to build formal processes rather than leave work to one individual. "This will take an investment in potentially additional staff or people power," he said, noting that regulations and requirements will continue to change and that automation still requires human oversight.

Panelists recommended three broad process changes: (1) institutionwide coordination across compliance, legal counsel, admissions, registrars, IT, academic affairs and program subject-matter experts; (2) defensible, documented workflows for state research, public and direct disclosures, and written attestation exceptions; and (3) periodic reviews and documentation showing when reviews occurred so institutions can meet notification duties (for example, the 14-calendar-day requirement to notify current students when a program moves to a "does not meet" status).

On written attestations, Katherine Kinsky explained the essential elements institutions should capture in the attestation form: the students name, the students current location at the time of initial enrollment, and the students declared intended state for licensure or employment. The Department of Education provided no template, panelists said, so institutions must craft forms locally and seek legal review.

Regarding technology, the panel said only a small fraction of institutions have fully automated disclosure workflows; many operate with spreadsheet-driven systems and manual processes. Panelists urged institutions that pursue automation to include human review steps for unusual or borderline cases and to document manual checks.

Panelists closed by encouraging use of peer networks and professional resources such as the State Authorization Network (SAN) and licensure-research platforms to share templates, sample attestations, and best practices; they also recommended using survey data to make the case to campus leadership for resources and staffing to sustain compliance operations.