Student Location Policy for Certifications or Professional Licensure Programs
Determination of Student Location for State Authorization and Program Licensure Disclosures
Background
SUNY Downstate Health Sciences University is committed to complying with federal and state rules and regulations regarding the operation of higher education institutions in every state in which it enrolls students in programs leading to certifications or professional licensure. This practice, known as State Authorization, relates to all out-of-state activities ranging from fully online programs to experiential learning activities in face-to-face courses.
These procedures outline how SUNY Downstate Health Sciences University determines student location to comply with federal regulations on state authorization (34 CFR 600.9) and disclosure of information about licensed programs (34 CFR 668.43). These procedures do not apply for any other determination of student location, including tuition residency, IPEDS reporting, or other purposes.
Policy
Student location is determined at the time of initial enrollment at the University. For purposes of this policy, the student location is the State where the enrolled student resides and is based on the physical location of the student. For a prospective student, this is the State of the prospective student’s residency at the time the student has applied for admission, intends to enroll, and is then entered into SUNY Downstate Health Sciences University's Banner System by the Office of Admissions (based on the address that is entered in their application for admission).
For students with a permanent address that does not include a U.S. State or territory (e.g., students living outside the United States), their location will be considered the State of New York.
Students are required to maintain an accurate permanent (“home”) and local address in the Banner system.
This determination of location differs from determination of residency, which is a SUNY policy set for the purposes of determining eligibility for in-state tuition at SUNY state-operated campuses.
More information about the determination of residency can be found on the NYS Residency page within the Admissions website.
Change of Address. The student location designation will remain in effect unless and until a student
changes the U.S. State or territory listed in the student’s permanent address using
a change of address form with the Registrar’s office. Once a new U.S. State or territory
is registered into the Banner System, for any enrolled student. SUNY Downstate will
consider that date of submission as the effective date of a student’s revised location
for the purposes of this policy.
Background
This policy is in relation to the university certification procedures for Title IV participation and consumer protection so that students do not expend their time and funds on a program that will not meet their occupational goals and, likewise, so that federal funds are not expended for such programs. Amendment to existing regulation 34 CFR 668.14(b)(32)(ii) 32, effective July 1, 2024, impacts Title IV eligible programs that lead to licensure or certification for an occupation, no matter program modality and no matter if the institution participates in NC-SARA, as professional licensure disclosures are reviewed during the SARA application approval process.
State Authorization § 600.9(c)(2)(ii) requires a policy on Student Location that must be provided to the Secretary of Education upon request. Student locations will no longer correspond with the student’s state of residence, but instead with the student’s physical location. Institutions providing distance or correspondence education to students located outside of the state where the institution is physically located must meet the student’s state’s requirements for it to be legally offering distance or correspondence education in that state (State Authorization §600.9(c)(1)(i)). Institutions must determine the state in which a student is located both at the time of the student’s initial enrollment in an educational program and upon formal receipt of information from the student that their location has changed (State Authorization § 600.9(c)(2)(iii)).
Responsibility
Students may not be enrolled in any courses or program while in a location that is not authorized. Moreover, students may not be enrolled in and/or complete a licensure program while in a location where the licensure program does not meet educational licensure requirements. The only exception to this requirement is if a student submits an attestation stating they are aware the program does not meet the requirements but wishes to continue the program. This exception refers to the licensure program requirement only.
Procedure
To comply with Institutional Information § 668.43(c), Licensure Requirement Direct Disclosures, the Admissions Office is the first point of verification and contact with prospective students applying to programs leading to certification or professional licensure. As part of the application process, students will receive notice asking them to review the state authorization public disclosures webpage, which includes locations where the program is approved and meets educational licensure requirements.
They will also be required to complete an attestation form before being considered for admission to SUNY Downstate Health Sciences University. The Attestation form will be a part of their required application material. The student may not be considered for admission in the program unless they submit an attestation that they understand the program does not meet educational licensure requirements in their location. Students failing to complete the attestation form will not be considered for admission and could be dismissed from their program.
The applicable programs have been identified by SUNY Downstate and copies of the disclosures are available on the SUNY Downstate Professional Licensure website. The Admissions Office will require the form to be complete as a part of the application process which will explain the policy and act as direct disclosure notification regarding the professional license disclosure to any student in one of the applicable programs before acceptance and acknowledgement.
The Admissions Office will send Direct Disclosure notification regarding the Professional Licensure Disclosures to any new or incoming student who changes their permanent (mailing) address to an out-of-state address or to students that have a permanent (mailing) address out-of-state and change their program of study to one of the applicable programs. The Registrar's Office will manage a Direct Disclosure notification regarding the Professional Licensure Disclosures to any current students who change their permanent (mailing) address to an out-of-state address or to students that have a permanent (mailing) address out-of-state and change their program of study to one of the applicable programs. The disclosures are sent within 14 calendar days of the change being made. Students in these situations are flagged by the Registrar’s office after a change of address is submitted.
Academic Advisors of students within programs that lead to certification or professional licensure will follow up with students who complete the attestation form to ensure full understanding of the attestation form and strongly encourage students to contact their state’s licensure entity to review all licensure and certification requirements imposed by their state(s) of choice.
Attestation Form
Federal regulation, § 668.14(b)(32)(i) and (ii), requires students to complete an attestation at the time of initial enrollment or change of address outside of New York State when they are enrolled in a professional licensure or state certification program. The attestation serves as a crucial tool to ensure that students engage in the decision-making process with full awareness and consent.
SUNY Downstate is committed to complying with federal regulations and demonstrating transparency. SUNY Downstate Health Sciences University has implemented a robust student attestation process to ensure that students are fully informed about how the University’s professional licensure and certification programs align with the educational standards of a state or territory, empowering them to make informed decisions about their education and future career paths.
Relevant Standards, Codes, Rules, Regulations, Statutes, and Policies
Licensure Disclosure Statement Regulation: 34 CFR 668.43(a)(5)(v) (https://www.federalregister.gov/d/2023-22785/p-1961)
Student Location Determination Regulation: 34 CFR 600.9(c)(2) (https://www.ecfr.gov/current/title-34/part-600/section-600.9#p-600.9(c)(2))
Last Updated: March 27, 2026