Educational Institutions to Meet New Professional Licensure Disclosures

Effective July 1, 2020, a new federal policy from the U.S. Department of Education requires educational institutions to make public whether their programs will fulfill educational requirements for specific professional licensure or certification and to inform their prospective students whether their degree upon graduation will qualify them to work in the state where they are located. This requirement applies to in-person as well as distance education programs leading to professional licensure and includes educational programs in the field of respiratory care.

A link to the regulations is provided in the Resource section below. However, for your convenience, we have highlighted the key provisions and notes below:

§ 668.43(a)(5)(v) General Disclosure of Whether Program Meets Licensure or Certification Requirements: Institutions are required to make public whether a program will fulfill educational requirements for a specific professional licensure or certification required for employment in an occupation if the program is designed to or advertised as meeting such requirements. Institutions will be required to make public, for each state, whether the program did or did not meet such requirements, or whether the institution had not made such a determination.

Notes: These requirements apply to all programs offered via all modalities (distance education and not) that are designed to meet the educational requirements for a specific professional license or certification that is required for employment in an occupation, or is advertised as meeting such requirements.

§ 668.43(c) Licensure Requirement Direct Disclosures

Requirements: The final regulations will require direct disclosure to individual students in circumstances where an offered program has been determined not to meet or where the institution has not made a determination as to whether the program meets the education requirements for licensure in a state where a prospective student was located, as well as to students currently enrolled in a program that ceased to meet such requirements.

Notes: For students currently enrolled, institutions would have 14 calendar days to directly disclose that they had made a determination that a program did not meet state licensure or certification requirements for the state in which the student is located. For prospective students, the disclosure must be made prior to the student’s enrollment in the program. The disclosures must be made directly to the student in writing, which may include through email or other electronic communication.

The Commission on Accreditation for Respiratory Care (CoARC) notified its program directors of these new requirements in late September. They have also provided several resource documents on their website to help their programs address the new federal regulations, noting that each state has somewhat different specific licensure requirements. The AARC agreed to provide these resources to our program managers who may be impacted by these new provisions. Tom Smalling, Ph.D, RRT, RRT-SDS, RPFT, RPSGT, FAARC, Chief Executive Officer of CoARC, has offered to be the contact for programs needing additional assistance. You may reach him at

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