Student Location and Licensure Notification Policy
| Policy number | 03-10 |
| Responsible office | Office of the Provost and Vice President for Academic Affairs |
| Enforcement official |
Enforcement official
Senior Vice Provost for Academic Affairs, Budget and Operations
|
| Classification | Board of Trustees-delegated Policy |
| Category | Academic Affairs |
Statement of policy
Federal regulations require institutions of higher education to make certain disclosures (including professional licensure information) based on their students’ respective locations and to notify students if an institution’s educational program does not meet educational requirements for licensure or certification in the student’s state of residence. The University will determine a student’s location for purposes of disclosing professional licensure information specific to the U.S. State or Territory which the student disclosed as their residence (1) at time of their initial enrollment with WMU or (2) in a formal notification to WMU of a change in the student’s location, such as a written attestation by the student that they intend to seek employment in a State different from that of student’s previously recorded location.
In accordance with federal regulations implemented by the U.S. Department of Education under Title IV, specifically 34 CFR §668.43(a)(5)(v) and 34 CFR §668.43(c), institutions of higher education such as Western Michigan University (“WMU” or “University”) must disclose – with regard to each of its academic programs which lead to enrolled students being professionally licensed in any of the U.S. 50 States or 9 Territories – whether the program meets the educational requirements for licensure or certification in the State or Territory where prospective and enrolled students WMU’s relevant programs are located. This is a compliance policy, for determining and documenting WMU student locations in accordance with Title IV disclosure and licensure requirements.
This policy does not supersede any other University policy that determines a student’s Michigan residency for any other purpose, and WMU will not use the definitions herein for its tuition assessments.
Summary of contents/major changes
New policy
- Purpose of Policy
The purpose of this policy is to establish a consistent and documented procedure for WMU to determine, monitor, and document the location (not residency) of its prospective and enrolled students in academic programs, in order to provide required disclosures to those students in compliance with 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c), as amended on October 31, 2023 to take effect July 1, 2024.
- Stakeholders Most Impacted by the Policy
This policy applies to all prospective and enrolled certificate/degree seeking students in all University academic programs, including on-campus, online, hybrid, and distance education formats, especially programs leading to professional licensure or certification. This policy does not determine a student’s residency for purposes of tuition or other classifications not required by 34 CFR § 668.43.
- Key Definitions
3.1 Initial enrollment: The time at which a student applies to, enrolls in or is admitted to a University academic program, but has not yet registered for courses in that program or major leading to professional licensure or certification. For programs with no program-specific admissions process, the student’s “initial enrollment” shall be defined as the time when the student initially declares their major.
3.2 Professional Licensure or Certification Program: A graduate or undergraduate University academic program designed to meet educational requirements for a specific professional license or certification required for employment in an occupation, or advertised as meeting such educational requirements.
3.3 Prospective Student: An individual who has applied to or intends to enroll in a University academic program, but has not yet commenced enrollment.
3.4 Student Location: The U.S. State or Territory of the permanent address which a student formally provides to University, as of the time of the student’s Initial Enrollment in a University Professional Licensure or Certification Program and, where applicable, when a student formally notifies University of a change to the student’s permanent address.
- Full Policy Details
4.1 Procedures
The University will use a student’s location as determined by this policy to make any general educational program disclosures required by 34 CFR § 668.43(a)(5)(v) and any individual educational program disclosures required by 34 CFR § 668.43(c)(1) and (2). When requested, and subject to applicable privacy laws, the University Registrar or their designee will make the determination regarding a student’s location, together with any supporting documentation, available to the Secretary of Education.
4.2 Determination of Student Location
4.2.1 The University’s procedure for determining student location shall be applied consistently to all students. The University will document all location determinations as required under 34 CFR §668.43(c)(3)(ii)(A). The address on file in University’s official student record system is considered the authoritative source for student location.
4.2.2 An enrolled student’s location shall be the student’s self-reported “permanent home address” at the time of the student’s Initial Enrollment or as subsequently updated in University’s system following formal notification by the student of a change in their permanent home address.
4.2.3 A prospective student’s location shall be the student’s “permanent home address” in University’s official student records system (i.e., Banner) at the time of the student’s application for admission to the relevant academic program.
4.2.4 If a student’s location is outside the United States (not in any U.S. State or Territory), the University shall record the student’s (foreign) country of residence as the student’s location.
4.2.5 The University will not record a student’s temporary, travel, or other non-permanent student address as the student’s location for purposes of this Policy.
4.2.6 If a student refuses or fails to identify any location or permanent address by their Initial Enrollment or other relevant time, the University will record the student’s location as: “No U.S. State or Territorial Location Identified.”
4.2.7 Effective Date. A change in student location shall be effective as of the date the student updates their address or on the date the University receives the notification, whichever occurs first.
4.2.8 A student who enrolls in a program that holds instruction mainly at a physical location on campus (on-campus instruction) shall be considered in Michigan. This determination is based on the student being located (in part exclusively) in Michigan while receiving instruction and enrolling in a program designed primarily to lead to licensure in the state of Michigan.
4.2.9 A student enrolling in a program offering instruction in a hybrid learning format will be considered in Michigan.
4.2.10 A student enrolling in a program offered exclusively through distance education will be considered in the state where they reside and is based on the permanent home address in the student information system.
4.2.11 For students that do not have a permanent address in `the United States and are not physically located in a U.S. State or Territory, the student’s location will be considered Michigan even if the student is not concurrently enrolled in at least one on-campus course.
4.3 Ongoing Monitoring and Changes in Location
4.3.1 Triggers for University Review of Student Location. The University will review a student’s location when:
4.3.1.1 A student official notifies the University of an update to the student’s location;
4.3.1.2 A student enrolls in a program leading to professional licensure;
4.3.1.3 A student begins a supervised field experience, clinical placement, or internship; or
4.3.1.4 The institution becomes aware of a student’s location change through University’s administrative processes.
4.4 Student Responsibilities
4.4.1 Student Responsibilities. It is the student’s responsibility to promptly and accurately notify the University of the student’s location, as well as of any change in student’s location by updating their address in the designated student system. If a student fails to disclose or update their permanent address when required, the University shall assign the student a default Michigan residency.
4.4.2 Student Attestation. If a student’s location is determined at time of Initial Enrollment to be in a state where WMU’s academic program does not meet the requirements for licensure or certification in that state, and the student wishes to enroll in the academic program despite the fact that it does not meet the requirements of that student’s location state, the student may still enroll, PROVIDED the student provides a signed (and notarized?) attestation before enrolling in the program.
4.4.2.1 The attestation must indicate that the student intends to seek licensure and employment in a specific state in which the University’s academic program does meet the requirements for licensure or certification. Student must indicate the specific state by name in the attestation.
4.4.2.2 Students who fail to provide a required attestation prior to the enrollment deadline will not be allowed to enroll in the program for the term or semester in question. The student may later enroll in the program if the required attestation is provided prior to the then-current enrollment deadline.
4.4.2.3 The relevant College or Department’s assigned program administrator(s) for each Professional Licensure or Certification academic program shall notify students when any required student attestations are completed and documented (if necessary).
4.5 University Recordkeeping and Compliance
4.5.1 The University’s determination of a student’s location will be maintained as a part of the student official University record, and WMU will make it available to the U.S. Secretary of Education upon request.
4.5.2 The Office of the Registrar (or designated office) is responsible for managing the student location database and ensuring compliance with 34 CFR § 668.43.
4.5.3 The University’s record of a student’s location for purposes of this Policy shall remain in effect unless and until a student officially requests that the Registrar (A) update University’s official record to change the U.S. state or territory listed as the student’s permanent address, or (B) change the student’s recorded location for the purposes of this Policy without changing the student’s permanent address. The change to student’s location will be effective as of the date Registrar receives the student’s official request through the University’s established system.
4.5.4 Record Retention. The University Registrar will maintain an official record of all student location determinations made under this Policy, in accordance with applicable federal and institutional record retention policies.
4.6 Required Disclosures
4.6.1 Method of Delivery. These required individual written notices may be delivered to the student via email or other electronic communication.
4.6.2 General Disclosures Required under 34 CFR § 668.43(a)(5)(v).
The University shall make readily available to enrolled and prospective students information relevant to University’s academic programs, costs, professional licensure eligibility, and other relevant information specified in § 668.43(a), including lists of all U.S. States and Territories for which the University has determined that its academic programs either meet or do not meet the respective educational requirements for licensure or certification for relevant occupations, and a list of all States and Territories for which the University has not yet determined whether University’s curricula meet the respective educational requirements for licensure or certification in relevant occupations.
4.6.3 Individual Notifications Required under 34 CFR § 668.43(c). The University will disclose state-specific professional licensure information in writing via email to all current and prospective students, using the student’s assigned university (wmich) email address, at the following times:
- At the time of the student’s initial enrollment (semester); and
- Within 14 days of the student formally notifying the university of a change in location, if the student is already enrolled in a professional licensure program.--
4.6.4 Notification by Program Administrator. The designated program administrator(s) for each Professional Licensure or Certification Program shall provide individual written notice to that Program’s enrolled and prospective students:
- Before a prospective student's enrollment in the program, if that student’s location is in a State or Territory (1) where University has determined that its curriculum does not meet licensure or certification requirements, or (2) where University has made no determination regarding whether the program’s curriculum requirements in that State or Territory.
- the University has made a determination under 34 CFR § 668.43(a)(5)(v) that the program's curriculum does not meet the educational requirements for licensure or certification in the State or Territory of the student’s location, or if the University has not determined whether the program's curriculum meets the State or Territory educational requirements for licensure or certification in the prospective student’s State or Territory of location.
- Within 14 calendar days of making a determination that an academic program in which an enrolled student is currently enrolled does not meet the student’s location State’s requirements.
4.6.5 Office of Admissions. The University’s Office of Admissions also tracks licensure information of students admitted to WMU in programs designed or advertised to meet educational requirements for licensure. This Office works collaboratively with the Registrar, Office of Institutional Effectiveness, and Program Administrators in relevant Colleges and Departments to help ensure that appropriate licensure disclosures are sent prior to their enrollment or making a financial commitment to the University. Graduate College..
4.6.6 Office of Institutional Effectiveness. The Office of Institutional Effectiveness shall:
- regularly furnish [to whom?] reports of University students’ updates locations;
- flag [where?] changes to a student’s location state; and
- notify a prospective or enrolled student who has changed their official location to a state or territory where their selected academic program does not meet educational requirements for licensure or certification, or a state or territory regarding which University has not yet determined whether the academic program meets educational requirements for licensure or certification, or is otherwise exempt.
4.7 Accountability.
Consequences for non-compliance with this Policy include:
Students: For students, failure to follow this Policy could lead to sanctions under the Student Code, up to and including expulsion.
WMU Employees (Faculty, Staff): The University must comply with federal requirements. Failure to follow this policy and any associated procedures may subject WMU employees to disciplinary action, up to and including dismissal from employment by the University, consistent with applicable procedures and collective bargaining agreements. For administrators, faculty and staff, failure to follow this Policy could lead to disciplinary action up to and including dismissal consistent with Human Resources policy and applicable bargaining agreements.
- Related Procedures and Guidelines
- Additional Information
This policy also complies with State Authorization Reciprocity Agreements (SARA) Policy 5.2: Programs leading to professional licensure.
- FAQs
Note: FAQs are informational only and not officially part of the policy. They may be revised as needed without following the policy review and approval process.
Q1: Where are professional licensure disclosures posted?
The University will maintain website information for professional licensure disclosures at wmich.edu/state authorization/disclosures. Additionally, each program will provide licensure disclosures information on their websites—
Related Policies:
References:
SARA Policy Manual 24.1 Section 5.2: Programs leading to professional licensure
| Effective date of current version | May 20, 2026 |
| Proposed date of next review | May 20, 2029 |
| Certified by |
Senior Vice Provost for Academic Affairs, Budget and Operations |
| At the direction of |
Interim Provost and Vice President for Academic Affairs |