91ÉçÇø

In compliance with federal Title IV requirements and NC-SARA policy for online/distance education programs, 91ÉçÇø defines a student's location for the purpose of licensure/certification disclosers as outlined in the policy below.

Policy Title	Student Location & Professional Licensure or Certification Disclosure [DRAFT - Awaiting Approval]
Responsible Offices	Office for Online and Innovative Education Office of Institutional Research and Analysis
Policy Type	Legal and Compliance
Policy Number	9xx
Last Revision Date	08-13-2026

Scope of Policy

Before enrolling in an online/distance education program intended to satisfy a particular state’s educational requirements for the practice of a particular occupation, students must ascertain that the program actually does meet the requirements of the state in which they intend to practice. 91ÉçÇø is required to provide related disclosures to online/distance education students based on their location at the time of admission or subsequent enrollment; therefore, it is imperative that students maintain accurate records of their location throughout any online/distance education program that leads to professional licensure or certification.

This policy therefore applies to all students enrolled in academic programs leading to licensure or certification, particularly those enrolled in online or distance education courses who may reside in a state other than New York.

Definitions

Professional Licensure: A formal acknowledgement by a state or other governmental agency indicating that an individual has met the established standards of practice for a particular regulated profession and has legal permission to practice that profession in the designated state or jurisdiction.

Student location: In general, student location is defined as the location where a student is physically present during the educational activity. For prospective students, their location for the purpose of this policy is determined at the time of initial application based on the permanent address provided on their official application. For enrolled students, location is determined by the active permanent address on file in the BU Brain Student Information System.

Policy Statement

In compliance with the United States Department of Education (USDOE) regulations (34 CFR § 668.43) and the State Authorization Reciprocity Agreements (NC-SARA) Manual, 91ÉçÇø must determine the state in which a prospective or currently enrolled student is located for the purpose of issuing required professional licensure and certification disclosures. This policy outlines the procedures by which 91ÉçÇø University establishes a student’s location.

At matriculation, student location will be the campus address if the student is living on campus or the permanent address otherwise. For online/distance education students, location is defined by the state in which the student is physically present while completing coursework. Students must review and appropriately update their physical location at the time of registration for each term or at any point during enrollment if it has changed from their previous location.

It is the official responsibility of the student to maintain an accurate and up-to-date permanent address on record with the University and to update their address by following the instructions on the Registrar’s Manage Contact Information page if any changes are necessary: /registrar/student/manage-contact.html

For the purposes of licensure/certification disclosures, students must report a change of permanent address or relocation to a different state by formally updating their contact information through the Office of the Registrar within 10 to 14 days. A change of location is officially recognized by the University on the date the address update is officially processed and recorded in the 91ÉçÇø Student Information System. A student’s location change may affect:

• Professional licensure eligibility
• Ability to participate in experiential placements
• Cost of attendance or aid eligibility

If a student enrolled in a program leading to professional licensure officially requests a change in their location to a state where the program does not meet the education requirements for licensure, 91ÉçÇø will issue a direct, written disclosure to the student regarding this status within 30 days of the location change being recorded.

For out-of-state learning placements, the physical location of the experiential site also constitutes the student’s location. Programs with such placements gather information on placement locations and provide it to the Vice Provost for Online and Innovative Education.

Student Complaints

91ÉçÇø is a member of the National Council for State Authorization Reciprocity Agreements (NC-SARA) and follows the complaint resolution policies and procedures outlined within the SARA Policy Manual and summarized on the SARA Student Complaints page. Consumer protection complaints resulting from distance education courses, activities, and operations may be submitted to the Vice Provost for Online and Innovative Education at 91ÉçÇø for investigation and resolution. If a student is dissatisfied with the campus-based resolution, a concern may be submitted to System Administration of the State University of New York as outlined at . If still not satisfied, a complaint may be submitted, within two years of the incident about which the complaint is made, to the New York State Education Department as outlined on their webpage. A more detailed description of the NC-SARA Student Complaint Process is available on 91ÉçÇø’s Student Consumer Information webpage.

Please note, this process is only for consumer protection issues (for examples, see Section 4 of the ); it does not include complaints related to grades or student conduct violations, both of which are to be addressed via non-SARA processes (see the section on Student Concerns and Complaints on the 91ÉçÇø Student Consumer Information webpage). Additionally, this process is only for distance education students located in another SARA-participating state (as of January 1, 2026, this includes all states except California), whereas other distance education students, including those located in New York State, should follow non-SARA processes  as described on the Student Consumer Information webpage of the University.