Nursing Program Authorization

If you run a nursing program that enrolls students from multiple states—especially online programs—you’re required to tell students whether your curriculum leads to licensure in their state. This isn’t optional. It’s federal law under 34 CFR 668.43.

Here’s what compliance officers and program administrators need to know.

The Disclosure Requirement

Under 34 CFR 668.43, institutions must provide prospective and enrolled students with information about professional licensure requirements for programs designed to meet such requirements.

For nursing programs, this means:

1. Direct disclosure: For each state, indicate whether your program meets, does not meet, or whether you haven’t made a determination about that state’s nursing licensure requirements.

2. Contact information: Provide students with the relevant state board contact info so they can verify requirements themselves.

3. Accessibility: This information must be publicly available—not buried in a catalog PDF or behind a login.

What “Meets Requirements” Actually Means

For a nursing program to “meet” a state’s licensure requirements, your curriculum must align with what that state’s Board of Nursing requires for initial licensure. This typically includes:

• Education hours: Does your program meet the minimum classroom and clinical hours?
• Curriculum content: Do you cover the required topics (pharmacology, mental health, etc.)?
• Clinical requirements: Do you meet the clinical rotation hours and settings the state mandates?
• Accreditation: Is your program accredited by an agency the state recognizes (CCNE, ACEN)?

The tricky part: requirements vary by state. Some states require 500 clinical hours. Others require 900. Some have specific curriculum mandates (like California’s implicit bias training). Miss one element, and your program may not meet that state’s requirements.

NC-SARA vs. Licensure Disclosures

A common misconception: “We’re NC-SARA approved, so we’re covered.”

NC-SARA (National Council for State Authorization Reciprocity Agreements) handles interstate authorization for distance education. It lets you offer online programs to students in other states without getting separate authorization from each state’s department of education.

NC-SARA does not cover professional licensure.

Even if NC-SARA allows you to enroll a student from California, you still must disclose whether your program leads to RN licensure in California. Those are separate regulatory frameworks.

What Compliance Officers Actually Need

To maintain accurate disclosures, you need current data on:

For each of the 50 states:

• Education requirements (ADN, BSN, credit hours)
• Clinical hour minimums
• Required curriculum topics
• Approved accreditation bodies
• Background check requirements
• Any state-specific mandates

And you need to track changes. State boards update requirements regularly. A state might increase clinical hours, add a new curriculum requirement, or change their accreditation standards. If you don’t catch the change, your disclosure becomes inaccurate—and that’s a compliance problem.

Practical Approaches

Manual Tracking

Some schools assign staff to manually review each state board website quarterly. This works but is labor-intensive:

• 50 state boards to monitor
• Multiple license types (RN, LPN, APRN)
• No standardized format across states
• Changes often buried in board meeting minutes

Budget 80+ hours for a thorough annual review, plus time for ad-hoc updates when you hear about changes.

Data Services

Third-party services maintain state-by-state licensure databases and track changes. Benefits include:

• Monthly or quarterly updates
• Source citations for verification
• Structured data for website integration
• Change alerts when requirements shift

The trade-off is cost, but for programs with students in 30+ states, the time savings often justify it.

Embeddable Tools

Some data providers offer embeddable widgets you can add directly to your program pages. Students can check requirements for their specific state without navigating away from your site. This also demonstrates proactive compliance—you’re not just meeting the minimum, you’re making the information accessible.

State-Specific Complications

Non-Compact States

If your student lives in California, New York, or another non-compact state, your disclosure matters more. They can’t rely on a multistate license—they’ll need a license specifically from their home state’s board. Make sure your curriculum actually meets that state’s requirements before enrolling.

APRN Programs

Advanced practice programs (NP, CNM, CRNA, CNS) have additional complexity. Beyond basic RN requirements, you’re dealing with:

• Certification body requirements (ANCC, AACN, etc.)
• State-specific prescriptive authority rules
• Collaborative practice agreements in some states
• The developing APRN Compact (currently not operational)

Clinical Placement States

If students complete clinical rotations in states different from their home state, additional disclosures may be required. Some states require clinical sites to meet specific criteria.

Documentation Best Practices

1. Timestamp everything: Record when you last verified each state’s requirements.

2. Keep source URLs: Link to the actual board regulation or statute. Requirements should be traceable.

3. Version your disclosures: When you update information, archive the previous version with dates. If a student enrolled under an earlier disclosure, you may need to reference it.

4. Make it findable: Put licensure disclosures where students actually look—program pages, admissions pages, student portals. Not just a compliance document buried in a catalog.

The Bottom Line

State licensure disclosure isn’t going away. The Department of Education takes these requirements seriously, and state attorneys general have increasingly pursued schools for misleading licensure claims.

For nursing programs serving multiple states, accurate disclosure requires:

• Current data on 50+ licensing jurisdictions
• A system to track changes
• Clear, accessible presentation to students
• Regular audits of your own compliance

The schools that get this right build trust with students and avoid regulatory headaches. The ones that don’t risk enrollment disruptions, legal action, and reputation damage.

---

Need help maintaining state licensure data? We provide 50-state nursing licensure datasets updated monthly with source citations, plus embeddable widgets for your program pages.