UNC Charlotte Academic Procedure: Student Learning & Professional Licensure Locations

i. Executive Summary

Some federal regulations require institutions to maintain an awareness of students’ locations.  This procedure specifically outlines how UNC Charlotte complies with: 

  • 34 CFR §600.9(c) (effective July 1, 2020) regarding the authorization of distance education programs by States, 
  • 34 CFR §668.14(b)(32) (effective July 1, 2024) regarding conditions that an institution must certify in order to participate in Title IV, and 
  • 34 CFR §668.43(a)(5)(v) and 34 CFR §668.43(c) (effective July 1, 2020, and as amended effective July 1, 2024) regarding general and direct disclosures an institution must make about programs that lead to licensure.

This procedure tracks student location with greater frequency, precision, and student-initiated flexibility than these regulations require, improving the correlation between the University’s student data and students’ actual intent.  This, in turn, makes better information and guidance for students possible.

ii. Procedure Statement

The following federal regulations require institutions to maintain an awareness of the State in which a student is located at a particular time: 

Two different address types make this tracking possible:

  • The Learning Location (LL) address type is used for compliance with 34 CFR §600.9(c), 34 CFR §668.14(b)(32)(i), and 34 CFR §668.14(b)(32)(iii). It tracks students engaged in regulated out-of-state academic activities and represents the answer to this question:  “From what State are you participating in online learning and/or an experiential learning placement (e.g., internship, student teaching, clinicals)?”
  • The Future Professional Licensure Location (PL) address type (shortened to “Future Prof Licensure Loc” in Banner due to field length limitations) enables compliance with 34 CFR §668.14(b)(32)(ii), 34 CFR §668.43(a)(5)(v), and 34 CFR §668.43(c).  For students in Professional Licensure Programs, this address type stores the State in which the student is expected to seek licensure and practice the profession.

Both LL and PL address types are permanently stored in Banner, the University’s enterprise student information system.  However, because these data are sometimes needed to make decisions before a student’s record is created in Banner, other University systems may need to calculate them on a temporary basis.  For example, in the case of a prospective student applying for admission to the University and to a Professional Licensure Program at the same time (e.g., any graduate-level Professional Licensure Program), the decision about whether a student is eligible to be enrolled in the Professional Licensure Program is made as the prospective student is filling in the application for admission before the prospective student record with its accompanying PL address is created in Banner.  (Banner records are created after students complete their applications and pay the fees.)  Thus, in the absence of an official Banner-stored PL address, the admissions management system, Slate, must determine what the student’s PL address would be in order to make the eligibility determination.  Whenever an auxiliary system determines a student’s PL or LL address because it does not yet exist in Banner, the system should, if feasible, push that information to Banner to be stored.  

The following explains how, when, and why addresses of both types are initially set for students and the conditions under which they change.

Learning Location

34 CFR §600.9 requires institutions to be legally authorized in States where its learners are located.  In order to know from which States authorization must be obtained, it requires the institution to “make a determination regarding the State in which a student is located at the time of the student’s initial enrollment in an educational program and, if applicable, upon formal receipt of information from the student, in accordance with the institution’s procedures, that the student’s location has changed to another State” (34 CFR §600.9(c)(2)(iii)).

UNC Charlotte collects students’ permanent (PR) and local mailing (MA) address data with their admission applications.  These addresses, along with other address types collected by other University systems, are stored in Banner and are corrected or updated by a variety of manual and automated processes as warranted.  Students themselves can update several types of their address data, including their permanent (PR) and local mailing (MA) addresses, using Student Self Service on the Student tab of my.charlotte.edu.   The University reminds active students to confirm their addresses every 180 days.  Despite these measures, the accuracy of some student address data still becomes questionable over time.  For this reason, UNC Charlotte augments student address information with course registration data–itself a form of “formal receipt of information from the student”–to determine each student’s Learning Location.  

Because a student’s address, registration, or program could change on any given day, students’ Learning Location is updated nightly by an automated process.  The logic for this process is as follows:

  1. For students enrolled in at least one face-to-face course held in a campus-based building or at a North Carolina-based site that is not an experiential learning placement, the state field of the Learning Location (LL) address is set to North Carolina.  (While those students may also be taking courses online in a given semester, because the students attend regular class sessions in North Carolina, it is unlikely that a larger portion of their time is spent learning while located in a State other than North Carolina.)  
  2. For students enrolled solely in online courses and/or experiential learning placements (e.g., internships, student teaching, clinicals), the state field of the Learning Location (LL) address is set using the student’s current address data.  (See below for more information about which address data to use.)
  3. For students who are not yet enrolled or registered for classes (e.g., students admitted for an upcoming term), Learning Location (LL) anticipates location at the Time of Initial Enrollment based on the students’ primary Program.  In other words, if the Program’s campus code is set to “Main or Dubois Campus” (M), the state field of the Learning Location (LL) address is set to North Carolina because the student can be reasonably expected to register for at least one face-to-face, on-campus course in such a program.  If, on the other hand, if the Program’s campus code is set to “Distance Education Campus” (D), the state field of the Learning Location (LL) address is set using the student’s current address data as described in the next section. 
  4. If the Learning Location (LL) address is to be set using the student’s address data AND  
    1. the student’s current local mailing (MA) address is not in a State (i.e., an international address), the state field of the Learning Location (LL) address is set to International or Undetermined (XX).
    2. the student’s current local mailing (MA) address is in a State, the state field of the Learning Location (LL) address is set to the state field of the student’s current local mailing (MA) address.
    3. no current local mailing (MA) address exists, the state field of the Learning Location (LL) address is set to the state field of the permanent (PR) address.
    4. neither a current local mailing (MA) address nor a current permanent (PR) address exists, the state field of the Learning Location (LL) address is set to International or Undetermined (XX).

Students with LL addresses set to XX represent a compliance risk for the University, and the situation requires follow up.  Since the University currently has no mechanism for seeking authorization in foreign countries, students located outside of the United States should not engage in online learning.  When an LL address is set to XX for this reason, the Out-of-State Academic Activities Coordinating Council (OoSAACC) will review the situation, seeking to reduce the University’s risk. Similarly, OoSAACC must investigate when the LL address of a student located within the United States is set to XX because the University must know the State in which the student is located in order to be sure it complies there.  In this situation, OoSAACC will simply find out the student’s current location and update records accordingly.

Future Professional Licensure Location

Due to the prevalence of online courses, no program at UNC Charlotte can claim that all of its courses are delivered in a face-to-face format. For this reason, all UNC Charlotte programs must be treated as distance education programs when determining the States for which the requirements of 34 CFR §668.14(b)(32) must be met. In other words, for all UNC Charlotte Professional Licensure Programs, the “State” referred to in 34 CFR §668.14(b)(32)(ii) is the State in which “students … are located, as determined at the time of initial enrollment in accordance with 34 CFR 600.9(c)(2); or … [attest] that they intend to seek employment.”  The definition of “time of initial enrollment” (see below) is key for initially determining what a student’s default PL address should be.

Beginning in July 2024, the way in which a student’s PL address is set or changed depends upon the student’s circumstances:

  1. For students applying for admission to the University and a Professional Licensure Program at the same time, the PL address will be determined as part of the application process, stored temporarily in Slate, and pushed to Banner along with the applicant’s other data.
  2. For students who have already been admitted to the University and are already taking classes (i.e., “continuing” students), the PL address can be set or changed using the Attestation process.

Setting the Future Professional Licensure Location in the Admissions Process

When a student applies for admission or readmission to the University and the application has collected both the student’s program of interest and the student’s local mailing (MA) address, Slate directs the applicant to a special popup if the student has selected a Professional Licensure Program.  This popup explains what a Professional Licensure Program is and why a Future Professional Licensure Location (aka PL address) is needed.  It then employs the following logic to display an initial/default value for the PL address:

  • If the Professional Licensure Program has a campus code of Main or Dubois Campus (M), the default Future Professional Licensure Location (PL) address is North Carolina because the student will be located in North Carolina at the time of initial enrollment (see Learning Location above and definition of Time of Initial Enrollment below for more details).  
  • If the Professional Licensure Program has a campus code of Distance Education Campus (D) and the state in the student’s local mailing (MA) address is a U.S. State, the default Future Prof Licensure Loc (PL) address is the state in the student’s local mailing (MA) address.
  • If the Professional Licensure Program has a campus code of Distance Education Campus (D) and the student’s local mailing (MA) address is outside of the United States, the default Future Prof Licensure Loc (PL) address is International/Undetermined (XX).

The applicant then has the opportunity to change this value by choosing a different U.S. State where the student intends to seek licensure/employment upon completion of the program.  (This opportunity to change the default PL address is itself a form of Attestation, described in further detail in the next section.)  When the applicant submits this information, Slate checks to see if the Professional Licensure Program chosen by the student satisfies the educational requirements for licensure in the state submitted.  If it does not, the applicant is informed of this and is given information about available options.  Under no circumstances will Slate allow an applicant to complete and submit an application if the Professional Licensure Program chosen does not satisfy licensure requirements in the applicant’s Future Professional Licensure Location.  This prevents applicants from ever paying application fees for a program that they were ineligible to enroll in.

Attestation Process

Recognizing that students’ plans change and that the State in which a student is located at the time of initial enrollment may not be the State in which the student may ultimately plan to practice, 34 CFR §668.14(b)(32) requires that students be allowed to “[attest] that they intend to seek employment” in a different State.  This attestation process is subject to some important limitations:

  1. The attestation process cannot be used to simply circumvent program eligibility rules.  A student from a State where a program does not meet the licensure requirements should not attest to a different State in order to be allowed to enroll in the program.  The University must, therefore, document “sufficient proof from the student themselves of their plans” and record “how the information about eligibility was conveyed to the borrower” in order to demonstrate “that they did understand their attestation” (88 FR 74643).
  2. Prior to the Time of Initial Enrollment, students can only attest to a State where the Professional Licensure Program satisfies the State’s educational requirements for licensure.  (Attesting to a State where the program does not satisfy licensure requirements makes the student ineligible to enroll in the program.)
  3. If a student who has already passed the Time of Initial Enrollment (i.e., a student who has already begun taking classes from a State where the program meets the State’s educational requirements for licensure) wishes to attest to a State in which the program does not satisfy the licensure requirements, that student may do so and remain in the program.  However, because it is important that the student understand the career implications such a change could have, this attestation will activate the Direct/Personalized disclosure process for Currently Enrolled Students described in the Academic Affairs Procedure: Programs for Licensed Professions.

At UNC Charlotte, the attestation process ultimately changes the student’s Future Prof Licensure Loc (PL) address to the State of the student’s choosing and happens in one of two ways depending on the student’s circumstances:  

  • Attestation as part of admission or readmission.  (Described in the previous section.)
  • Attestation by currently enrolled students.  Once they are admitted to the University and have begun taking classes, students who wish to set or change their Future Prof Licensure Loc (PL) address must do so via email sent from their charlotte.edu email address to the Registrar’s Office at ImageNowREG@charlotte.edu.  The subject line should read “Future Professional Licensure Location address change,” and the message should include all of the following:
    • Student Name.
    • 800 Number.
    • Name of the Professional Licensure Program in which the student is currently enrolled or wishes to enroll.
    • Request to update the student’s “Future Professional Licensure Location address” or “PL address.”
    • Name of the U.S. state, district, or territory where the student intends to seek licensure/employment.
    • Acknowledgement that, at present, the student’s current or future Professional Licensure Program does or does not satisfy the educational requirements for licensure in the student’s preferred state.  (Students can use the Inventory of Professional Licensure Programs to look up the program’s status in each state.) 

Additional information about this method of Attestation, including an example email, can be found on the Professional Licensure website.

Regardless of the method of Attestation, in case of an audit by the Department of Education, the University keeps the documentation (e.g., admission application, email) associated with Attestation in ImageNow.

iii. definitions

  • Attestation – Process by which students inform the University of the State in which they plan to seek employment in their profession after graduation from a Professional Licensure Program.  This process initiates a change in the students’ Future Professional Licensure Location (PL) address.
  • Enrolled – Prior to the start (i.e., first day of classes) of a semester, describes students who are registered to take at least one class in that semester.  From the start of a semester and beyond, describes students who participated or are participating in at least one class in that semester.  
  • Future Professional Licensure Location (PL) – One of many address types stored in Banner.  Used to record the State in which a student is expected to seek licensure and practice the profession.  “PL” is the code associated with this address type while “Future Prof Licensure Loc” is the description.  The value stored (i.e., State name) in this address type drives decisions about eligibility to enroll in Professional Licensure Programs and the disclosures required to be made to students in them. 
  • Learning Location (LL) – One of many address types stored in Banner.  Used to record the State from which a student engages in learning as part of a University Program.  Per 34 CFR §600.9 and University Policy 210, the institution must be authorized by this State in order to engage in academic activity there.  “LL” is the code associated with this address type while “Learning Location” is the description.
  • LL Address – Synonym for Learning Location (see above)
  • PL Address – Synonym for Future Professional Licensure Location (see above)
  • Professional Licensure Program – (see Programs for Licensed Professions procedure) 
  • Program – (see Programs for Licensed Professions procedure) 
  • State – A state, district, or territory of the United States.
  • Time of Initial Enrollment – The first day of class held once a student’s program has been set or changed in the student information system (i.e., Banner).  For example, if a student applies and is accepted for fall semester admission in June, that student’s Time of Initial Enrollment would be the first day of the fall semester.  Likewise, if a student requests a change of program midway through a semester, that student’s Time of Initial Enrollment for the new program would be the day that change was recorded in Banner, assuming the effective term of the new Banner record was the same as the current semester.  If the new record’s effective term differed from the current semester, that student’s Time of Initial Enrollment for the new program would be the first class day of the effective term recorded in Banner.

iv. Procedure Contacts

  • Authority: Office of the Provost and Vice Chancellor for Academic Affairs
  • Responsible Office: Office of the Provost and Vice Chancellor for Academic Affairs
  • Additional Contact(s): Out-of-State Academic Activity Coordinating Council (OoSAACC), School of Professional Studies

v. History

  • Established:  July 1, 2024

vi. Related Policies, Procedures, and Resources