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How do the 2025–2026 DOE criteria compare with state licensing boards' definitions of professional degrees?
Executive summary
The U.S. Department of Education’s 2025–2026 direction—forcing institutions that receive federal aid to disclose whether programs meet state professional licensure requirements and requiring timely student notices about program-state alignment—tightens federal oversight of “degree-to-license” claims and disclosure duties [1] [2]. State licensing boards, however, remain the ultimate arbiters of what counts as a qualifying professional degree: requirements still vary widely by state, by profession, and by board [3] [4].
1. Federal push: forcing transparency, not redefining degrees
The policy changes highlighted by WCET’s State Authorization Network (SAN) and NC-SARA focus on institutional disclosure obligations—institutions must determine whether curricula meet each state’s licensure rules, notify students within 14 days if they don’t, and comply with new SARA/DOE disclosure standards effective July 1, 2025—rather than creating a single federal definition of “professional degree” [1] [2]. This is a regulatory nudge toward transparency and consumer protection, not a usurpation of state boards’ authority [1].
2. State boards still set the substantive rules for licensure
State licensing boards retain primary control over what degrees, coursework, supervised hours, and exams qualify for a license. Reporting on counseling and mental‑health licensure shows each state prescribes unique educational thresholds—accreditation expectations, semester-hour minimums, and supervised practice requirements—that differ state to state [3] [5]. The Department of Education’s guidance points prospective licensees back to state boards for “the most timely and authoritative guidance” [4].
3. Practical consequences for institutions and students
Because boards vary, institutions must perform state-by-state assessments before recruiting or enrolling students who intend to practice in particular states. SAN warns institutions that if they determine a program does not meet a student’s state educational requirements, they have 14 calendar days to disclose that to the student [1]. NC‑SARA similarly requires institutions to notify whether an online or distance program will meet licensure requirements where the student is located [2]. The net effect: more upfront information, fewer surprises at graduation—but extra administrative burden on colleges.
4. Variation by profession makes a one-size-fits-all federal standard impractical
Professional requirements differ not only across states but across occupations. The Department of Education’s own materials and comparative state reports underline that licensure, certification, and reciprocity arrangements vary by occupation and are best interpreted at the state-board level [4] [6]. Analyses cited by stakeholders warn that universal, one-size-fits-all reciprocity laws can both exclude qualified applicants and admit underqualified ones because they overlay uniform criteria on dissimilar professions [7].
5. Interstate reciprocity and mobility remain contested terrain
There is active policy debate—state legislators, industry groups, and licensing boards are considering reforms to ease interstate mobility (universal recognition or reciprocity), but analysts caution such reforms can complicate or dilute standards [7]. Independent indexes and trackers show states differ in how restrictive or permissive they are, and some are pursuing “universal recognition” reforms while others maintain stricter local controls [8] [9].
6. Where this leaves students and employers
Students must verify program alignment with the licensing board in the state where they intend to practice; SARA and DOE require institutions to provide such disclosures and contact directories but do not themselves certify programs for licensure [2] [4]. Employers and credentialing entities should continue to rely on state board determinations and on board-specific comparators like Pennsylvania’s 50-state comparison reports for profession-specific details [6].
7. Limitations in current public reporting and what is not said
Available sources document the disclosure regime and universal variation across boards but do not offer a single federal definition of “professional degree” for 2025–2026; nor do they quantify how many programs will fail state-by-state checks under the new rules—those outcomes are not found in current reporting [1] [2]. There is also limited public data here about enforcement practices or how boards will handle cross‑jurisdictional program reviews going forward [1].
Bottom line: the 2025–2026 federal criteria increase institutional disclosure duties and student protections but do not replace or standardize state licensing boards’ long-standing, varied definitions of what constitutes a qualifying professional degree; students and institutions must still rely on state boards for the substantive determinations [1] [4] [3].