UNITED STATES DEPARTMENT OF EDUCATION 

OFFICE OF POSTSECONDARY EDUCATION

Issue Paper 6: Certification Procedures 

Session 1: January 18-21, 2022 

Issue: Certification Procedures

Statutory cites: §498 of the Higher Education Act of 1965, as amended 

 

Regulatory cites: 34 CFR 668.13, 668.14, 668.43

Summary of issues: 

The regulations at 668.13 spell out the procedures for certification to participate in the federal aid 

programs; and further regulations at 668.14 include the requirements of a Program Participation 

Agreement (PPA) that institutions enter into as a condition of participation in the aid programs. 

However, the Department is concerned that procedures certifying institutions of higher education

(institutions) to participate in the federal financial aid programs through a PPA are not sufficiently 

rigorous to adequately protect students and taxpayers.

Proposal:

The Department proposes changes that will provide for heightened oversight of institutions, particularly

those that have engaged in activities that are high risk for students or taxpayers. We believe that these 

proposed changes will help ensure that students have access to high-quality educational opportunities 

and are protected from predatory or abusive behaviors.

Specifically, under § 668.13, Certification Procedures, the Department proposes to:

1. Eliminate the requirement to automatically recertify institutions after one year on a monthto-month status if the Department has not made a decision. Current regulations require that 

the Department make a determination to grant or deny certification (provisional or full) within 

12 months for any institution’s application submitted on or after July 1, 2021. Under that 

provision, if the Department does not decide to grant or deny certification within 12 months, 

the institution is automatically be granted renewal of certification, which may be provisional. 

However, institutions that remain on month-to-month for an extended time are typically those 

that require the most extensive investigation before reaching a decision. Forcing a decision early 

could have substantial negative consequences for students and taxpayers. At the same time, the 

Department is working to improve its administrative processes and expand its resources to 

support more efficient and timely decision-making where possible.

2. Provide additional events that will lead to provisional certification, including when an 

institution has incurred repeated findings related to the same compliance concern from

program reviews or audits, or when the institution or an owner of the institution also owns 

another institution with liabilities owed to the Department. These are high-risk situations where

the Department might need to take further steps to protect students and taxpayers by putting 

the institution on provisional certification status.
Certification Procedures 2

3. Requires recertification for certain provisionally certified schools after two years. Namely, this 

provision applies to schools that were provisionally certified for reasons related to major 

consumer protection issues, such as pending or approved borrower defense or false certification 

claims.

Under § 668.14, which addresses PPAs, the Department proposes to:

1. Ensure that both private colleges and the companies that own them are required to sign PPAs. 

This will allow the Department to ensure owner entities with at least a 50 percent interest in the 

institution are liable for taxpayer losses that may be incurred by the institution.

2. Add State attorneys general to the list of entities that have the authority to share with each 

other and the Department any information pertaining to the institution's eligibility for or 

participation in the Title IV, HEA programs or any information on fraud and abuse. As members 

of the program integrity triad with oversight of colleges, is important to clarify that State 

attorneys general are included in information sharing between these entities.

3. Ensure that all programs that require programmatic accreditation and/or 

licensure/certification meet those requirements. Too often students have enrolled in programs 

without knowing that they will be unable to find employment in the recognized occupation, 

because the program does not meet the necessary requirements for employment. Institutions 

will now be required to have those necessary certifications or programmatic accreditation.

4. Seek feedback from the Committee on the appropriate maximum length of aid eligibility for a 

program that prepares students for gainful employment in a recognized occupation. The 

Department is aware of significant variations in the required lengths of programs that are tied 

to the same occupations across states. Longer programs result in significantly larger amounts of

student loan debt. For instance, an American Institutes for Research (AIR) analysis found that 

state requirements for cosmetology licenses range from 1,000 hours to more than twice as long,

at 2,300 hours, without any evidence of increased pay or better program outcomes associated 

with those longer programs. We offer multiple options, and seek additional feedback from the 

Committee on capping the appropriate length of aid eligibility by program type.

5. Establish additional conditions for use with provisionally certified institutions. The 

Department proposes a non-exhaustive list of conditions that may be used as a way to ensure 

institutions are aware of the requirements that may be applied to their schools. This allows the 

Department to formalize tools that are available now but are not typically used. 

Specifically, the Department may restrict the addition of new programs or locations, the rate of 

growth in enrollment of students or of Title IV volume, and the provision of a teach-out on 

behalf of another institution. Additionally, for an institution potentially at risk of closure, we 

propose to require submission of the following: a teach-out plan or agreement to the 

Department and to the institution’s recognized accrediting agency, a records retention plan to 

the Department, and/or the release of some holds on student transcripts. We additionally 

propose limitations on the owners with respect to approving the purchase of another institution 

while an institution is provisionally certified. For an institution that may have engaged in 

misrepresentations to students, exhibited aggressive recruiting practices, or violated incentive 

compensation rules, we may also require the institution to submit marketing and other 

recruiting materials for the review and approval of the Secretary.
Certification Procedures 3

6. Specifies the use of provisional conditions that will be applied to a proprietary institution 

seeking to convert to nonprofit status. These conditions include continued compliance with 

90/10 and gainful employment requirements, and the submission of reports on agreements 

with the former owner of the institution. For an institution that is certified as a nonprofit 

institution, or that converts to a nonprofit institution, conditions include reports on accreditor 

or state authorizer actions and new servicing agreements entered into by the school, as well as 

updates on IRS communications related to the school’s tax-exempt status.

Under § 668.43, Institutional Information, the Department proposes to:

1. Eliminate a disclosure requirement regarding licensure or certification prerequisites, to align 

with and reflect the proposed changes in 34 CFR 668.14 described above, which makes this 

disclosure requirement no longer necessary.

Proposed Regulations Redline

§ 668.13 Certification.

(a) Requirements for certification.

(1)

(i) The Secretary certifies an institution to participate in the title IV, HEA programs if the 

institution qualifies as an eligible institution under 34 CFR part 600, meets the standards of this 

subpart and 34 CFR part 668, subpart L, and satisfies the requirements of paragraph (a)(2) of this 

section.

(ii) On application from the institution, the Secretary certifies a location of an institution that 

meets the requirements of § 668.13(a)(1)(i) as a branch if it satisfies the definition of ‘‘branch’’ 

in 34 CFR 600.2.

(2) Except as provided in paragraph (a)(3) of this section, if an institution wishes to participate for the 

first time in the title IV, HEA programs or has undergone a change in ownership that results in a change 

in control as described in 34 CFR 600.31, the institution must require the following individuals to 

complete title IV, HEA program training provided or approved by the Secretary no later than 12 months 

after the institution executes its program participation agreement under § 668.14:

(i) The individual the institution designates under § 668.16(b)(1) as its title IV, HEA program 

administrator.

(ii) The institution's chief administrator or a high-level institutional official the chief administrator 

designates.

(3)

(i) An institution may request the Secretary to waive the training requirement for any individual 

described in paragraph (a)(2) of this section.

(ii) When the Secretary receives a waiver request under paragraph (a)(3)(i) of this section, the 

Secretary may grant or deny the waiver, require another institutional official to take the training, or 

require alternative training.

(b) Period of participation.
Certification Procedures 4

(1) If the Secretary certifies that an institution meets the standards of this subpart, the Secretary also 

specifies the period for which the institution may participate in a title IV, HEA program. An institution's 

period of participation expires no more than six years after the date that the Secretary certifies that the 

institution meets the standards of this subpart, except that -

(i) The period of participation for a private, for profit foreign institution expires three years after 

the date of the Secretary's certification; and

(ii) The Secretary may specify a shorter period.

(2) Provided that an institution has submitted an application for a renewal of certification that is 

materially complete at least 90 days prior to the expiration of its current period of participation, the 

institution's existing certification will be extended on a month to month basis following the expiration of 

the institution's period of participation until the end of the month in which the Secretary issues a 

decision on the application for recertification.

(3) In the event that the Secretary does not make a determination to grant or deny certification within 

12 months of the expiration of its current period of participation, the institution will automatically be 

granted renewal of certification, which may be provisional.

(c) Provisional certification.

(1)(i) The Secretary may provisionally certify an institution if -

(A) The institution seeks initial participation in a Title IV, HEA program;

(B) The institution is an eligible institution that has undergone a change in ownership that 

results in a change in control according to the provisions of 34 CFR part 600;

(C) The institution is a participating institution -

(1) That is applying for a certification that the institution meets the standards of this subpart;

(2) That the Secretary determines has jeopardized its ability to perform its financial 

responsibilities by not meeting the factors of financial responsibility under § 668.15 and 

subpart L of this part or the standards of administrative capability under § 668.16; and

(3) Whose participation has been limited or suspended under subpart G of this part, or 

voluntarily enters into provisional certification;

(D) The institution seeks a renewal of participation in a Title IV, HEA program after the 

expiration of a prior period of participation in that program; or

(E) The institution is a participating institution that was accredited or preaccredited by a 

nationally recognized accrediting agency on the day before the Secretary withdrew the 

Secretary's recognition of that agency according to the provisions contained in 34 CFR part 

6023; or

(F) The institution is a participating institution that has been provisionally recertified under the 

automatic recertification requirement in paragraph (b)(3) of this section. .

(ii) An institution’s certification automatically becomes provisional upon notification from the 

Secretary if—
Certification Procedures 5

(A) The institution triggers one of the financial responsibility events under §668.171(c) or (d) 

and, as a result, the Secretary requires the institution to post financial protection;

(B) The institution has received the same finding of noncompliance on more than one program 

review or audit; or

(C) The institution or an owner of the institution with control over that institution, as defined in 

34 CFR 600.31, also owns another institution with liabilities owed to the Department.

(iii) A proprietary institution's certification automatically becomes provisional at the start of a fiscal 

year after it did not derive at least 10 percent of its revenue for its preceding fiscal year from 

sources other than Title IV, HEA program funds, as required under § 668.14(b)(16).

(2) If the Secretary provisionally certifies an institution, the Secretary also specifies the period for which 

the institution may participate in a Title IV, HEA program. Except as provided in paragraphs (c) (3) and 

(4) of this section, a provisionally certified institution's period of participation expires -

(i) Not later than the end of the first complete award year following the date on which the 

Secretary provisionally certified the institution under paragraph (c)(1)(i)(A) of this section;

(ii) Not later than the end of the second complete award year following the date on which the 

Secretary provisionally certified an institution that had been fully certified for reasons related to 

substantial liabilities owed or potentially owed to the Department for discharges related to 

borrower defense to repayment or false certification, or for other consumer protection concerns 

as identified by the Secretary;

(iii) Not later than the end of the third complete award year following the date on which the 

Secretary provisionally certified the institution under paragraphs (c)(1)(i)(B), (C), and (D) (iii), (iii), 

(iv) or (c)(1)(ii)(e)(2) of this section; and

(ivii) If the Secretary provisionally certified the institution under paragraph (c)(1)(iv)(E) of this 

section, not later than 18 months after the date that the Secretary withdrew recognition from the 

institution’s nationally recognized accrediting agency.

(3) Notwithstanding the maximum periods of participation provided for in paragraph (c)(2) of this 

section, if the Secretary provisionally certifies an institution, the Secretary may specify a shorter period 

of participation for that institution.

(4) For the purposes of this section, “provisional certification” means that the Secretary certifies that an 

institution has demonstrated to the Secretary's satisfaction that the institution -

(i) Is capable of meeting the standards of this subpart within a specified period; and

(ii) Is able to meet the institution's responsibilities under its program participation agreement, 

including compliance with any additional conditions specified in the institution's program 

participation agreement that the Secretary requires the institution to meet in order for the 

institution to participate under provisional certification.

(d) Revocation of provisional certification.

(1) If, before the expiration of a provisionally certified institution's period of participation in a Title IV, 

HEA program, the Secretary determines that the institution is unable to meet its responsibilities under 

its program participation agreement, the Secretary may revoke the institution's provisional certification 

for participation in that program.
Certification Procedures 6

(2)

(i) If the Secretary revokes the provisional certification of an institution under paragraph (d)(1) of 

this section, the Secretary sends the institution a notice by certified mail, return receipt requested. 

The Secretary also may transmit the notice by other, more expeditious means, if practical.

(ii) The revocation takes effect on the date that the Secretary mails the notice to the institution.

(iii) The notice states the basis for the revocation, the consequences of the revocation to the 

institution, and that the institution may request the Secretary to reconsider the revocation. The 

consequences of a revocation are described in § 668.26.

(3)

(i) An institution may request reconsideration of a revocation under this section by submitting to 

the Secretary, within 20 days of the institution's receipt of the Secretary's notice, written evidence 

that the revocation is unwarranted. The institution must file the request with the Secretary by 

hand-delivery, mail, or facsimile transmission.

(ii) The filing date of the request is the date on which the request is -

(A) Hand-delivered;

(B) Mailed; or

(C) Sent by facsimile electronic transmission.

(iii) Documents filed by electronic transmission must be transmitted to the Secretary in accordance 

with instructions provided by the Secretary in the notice of revocation. 

(iv) The Secretary discourages the use of facsimile transmission for documents longer than five 

pages.

(4)

(i) The designated department official making the decision concerning an institution's request for 

reconsideration of a revocation is different from, and not subject to supervision by, the official who 

initiated the revocation of the institution's provisional certification. The deciding official promptly 

considers an institution's request for reconsideration of a revocation and notifies the institution, by 

certified mail, return receipt requested, of the final decision. The Secretary also may transmit the 

notice by other, more expeditious means, if practical.

(ii) If the Secretary determines that the revocation is warranted, the Secretary's notice informs the 

institution that the institution may apply for reinstatement of participation only after the later of 

the expiration of -

(A) Eighteen months after the effective date of the revocation; or

(B) A debarment or suspension of the institution under Executive Order (E.O.) 12549 (3 CFR, 

1986 comp., p. 189) or the Federal Acquisition Regulations, 48 CFR part 9, subpart 9.4.

(iii) If the Secretary determines that the revocation of the institution's provisional certification is 

unwarranted, the Secretary's notice informs the institution that the institution's provisional 

certification is reinstated, effective on the date that the Secretary's original revocation notice was 

mailed, for a specified period of time.
Certification Procedures 7

(5) The mailing date of a notice of revocation or a request for reconsideration of a revocation is the date 

evidenced on the original receipt of mailing from the U.S. Postal Service or another service that provides 

delivery confirmation for that document. 

§ 668.14 Program participation agreement.

(a)

(1) An institution may participate in any Title IV, HEA program, other than the LEAP and NEISP programs, 

only if the institution enters into a written program participation agreement with the Secretary, on a 

form approved by the Secretary. A program participation agreement conditions the initial and continued 

participation of an eligible institution in any Title IV, HEA program upon compliance with the provisions 

of this part, the individual program regulations, and any additional conditions specified in the program 

participation agreement that the Secretary requires the institution to meet.

(2) An institution's program participation agreement applies to each branch campus and other location 

of the institution that meets the applicable requirements of this part unless otherwise specified by the 

Secretary.

(3) An institution’s program participation agreement must be signed by—

(i) An authorized representative of the institution; and

(ii) For a proprietary or private nonprofit institution, by an authorized representative of an

entity with direct or indirect ownership of the institution if that entity has the power to exercise 

control over the institution. The Secretary considers the following as examples of circumstances 

in which an entity has such power--

(A) If the entity has at least 50 percent control over the institution through direct or 

indirect ownership, by voting rights, or by its right to appoint board members to the 

institution or any other entity, whether by itself or in combination with other entities or 

natural persons with which it is affiliated or related, or pursuant to a proxy or voting or 

similar agreement;

(B) If the entity has the power to block significant actions;

(C) If the entity is the 100 percent direct or indirect interest holder of the institution; or

(D) If the entity provides or will provide the financial statements to meet any of the 

requirements of 34 CFR 600.20(g), (h), or Subpart L of this part.

(b) By entering into a program participation agreement, an institution agrees that -

* * *

(17) The Secretary, guaranty agencies and lenders as defined in 34 CFR part 682, nationally recognized 

accrediting agencies, the Secretary of Veterans Affairs, State agencies recognized under 34 CFR part 

603 for the approval of public postsecondary vocational education, and State agencies that legally 

authorize institutions and branch campuses or other locations of institutions to provide postsecondary 

education, and State attorneys general have the authority to share with each other any information 
Certification Procedures 8

pertaining to the institution's eligibility for or participation in the Title IV, HEA programs or any 

information on fraud and abuse;

* * *

(26) If an educational program offered by the institution is required to prepare a student for gainful 

employment in a recognized occupation, the institution must -

(i) Demonstrate a reasonable relationship between the length of the program and entry level 

requirements for the recognized occupation for which the program prepares the student. The 

Secretary considers the relationship to be reasonable if the number of clock hours provided in 

the program does not exceed the greater of -

(A) One hundred and fifty percent of the minimum number of clock hours required for 

training in the recognized occupation for which the program prepares the student, as 

established by the State in which the institution is located, if the State has established 

such a requirement, or as established by any Federal agency; or 

(B) The minimum number of clock hours required for training in the recognized 

occupation for which the program prepares the student as established in a State 

adjacent to the State in which the institution is located; and 

(ii) Establish the need for the training for the student to obtain employment in the recognized 

occupation for which the program prepares the student;

* * *

(32) In each State in which the institution is located or in which the institution is otherwise required to 

obtain State approval under 34 CFR 600.9, the institution must—

(i) Ensure that each program is programmatically accredited, if such accreditation is required by 

a Federal governmental entity or by a governmental entity in the State; and

(ii) Ensure that each program satisfies the applicable educational prerequisites for professional 

licensure or certification requirements in the State so that a student who completes the 

program and seeks employment in that State qualifies to take any licensure or certification 

exam that is needed for the student to practice or find employment in an occupation that the 

program prepares students to enter.

* * *

(e) If an institution is provisionally certified, the Secretary may apply such conditions as are determined 

to be appropriate to the institution, including –

(1) For an institution that the Secretary determines may be at risk of closure—

(i) Submission of a teach-out plan or agreement to the Department and to the institution’s 

recognized accrediting agency;

(ii) Submission of a records retention plan to the Department; and

Commented [A1]: The Department is aware of significant 

variation across states in the minimum required length 

of programs tied to licensure in many states in a variety of 

fields. Otherwise-equivalent programs that require many 

more hours in one state can lead students in that 

state to spend more time in school and take 

on more student loan debt. For instance, an AIR analysis 

found that state requirements for cosmetology licenses 

range from 1,000 hours to more than twice as long, at 

2,300 hours. 

[https://www.ncsl.org/Portals/1/Documents/Labor/Licensin

g/Reddy_PBAExaminationofCosmetologyLicensingIssues_31

961.pdf] Requiring students, depending on the state, to 

spend much longer in equivalent programs results 

in those students using up more of their lifetime eligibility 

for Pell Grants or other federal financial aid, possibly making 

it harder for them to pursue later training.

The Department seeks feedback on the appropriate 

maximum length of aid for a gainful employment 

program in these situations where equivalent programs 

have substantially different lengths. The Department would 

not limit the discretion of the states to establish program 

length requirements but is concerned about the costs to the 

student of providing aid eligibility beyond the minimum 

state licensing requirements for programs that go far 

beyond the length that most institutions offer. Options 

might include, for example capping the length of aid for a 

program that receives federal aid at:

--The minimum clock hours required in the state, or the 

minimum plus a tolerance that allows programs to offer one 

additional course. For example, if a state requires 1,500 

hours for cosmetology, capping the aid at 1,500 or 

1,650 hours to allow for an additional course equivalent to 3 

credit hours.

--The minimum clock hours in a state 

in the same metropolitan statistical area (MSA) as the 

institution, if that state’s minimum hours are higher than 

the those in that institution’s state. For example, if an 

institution’s home state requires 1,500 hours for 

cosmetology and it is in the same MSA as a state that 

requires 1,800 hours, the minimum length would be 1,800.

--The lesser of the minimum number of hours required by 

the state or of the national median for the number of hours 

required. For example, if the national median is 1,500 

hours, aid at an institution in a state with a minimum of 

1,000 hours would still be capped at 1,000 hours, while aid 

at an institution in a state that requires 2,000 hours would 

be capped at 1,500 hours.

--Other permutations of the above ideas, such as allowing a 

tolerance of 125 percent above the minimum.

...
Certification Procedures 9

(iii) The release of holds on student transcripts over a de minimis amount, and the release of all 

holds on student transcripts in the event of a closure;

(2) Restrictions on the addition of new programs or locations;

(3) Restrictions on the rate of growth in enrollment of students or of Title IV volume;

(4) Restrictions on the institution providing a teach-out on behalf of another institution;

(5) Restrictions on the acquisition of another participating institution, which may include the posting of 

financial surety in an amount determined by the Secretary but not less than 10 percent of the acquired 

institution’s Title IV volume for the prior fiscal year. This surety is in addition to any other required 

surety;

(6) Additional reporting requirements, which may include, but are not limited to, cash balances, an 

actual and protected cash flow statement, student rosters, and interim unaudited financial statements;

(7) Limitations on the institution entering into a written arrangement with another eligible institution or 

an ineligible institution or organization for that other eligible institution or ineligible institution or 

organization to provide between 25 and 50 percent of the institution’s educational program under 34 

CFR §668.5(a) or (c); 

(8) For an institution alleged or found to have engaged in misrepresentations to students, engaged in 

aggressive recruiting practices, or violated incentive compensation rules, requirements to submit 

marketing and other recruiting materials for the review and approval of the Secretary; and

(9) Such other conditions as the Secretary deems necessary or appropriate.

(f) If a proprietary institution seeks to convert to nonprofit status following a change in ownership, the 

following conditions will apply to the institution following the change in ownership, in addition to any 

other conditions that the Secretary may deem appropriate—

(1) The institution must continue to meet the requirements under §668.28(a) and §668.28(b) until the 

Department has accepted, reviewed and approved the institution's financial statements and compliance 

audits that cover two complete consecutive fiscal years with passing 90/10 reporting under its new 

ownership, or until the Department approves the institution’s request to convert to nonprofit status, 

whichever is later;

(2) The institution must continue to meet the gainful employment requirements of Subpart Q of this 

part until the Department has accepted, reviewed, and approved the institution's financial statements 

and compliance audits that cover two complete consecutive fiscal years under its new ownership, or 

until the Department approves the institution’s request to convert to nonprofit status, whichever is 

later; and

(3) The institution will be required to submit regular and timely reports on agreements entered into with 

its former for-profit owner or affiliated or related persons or entities, so long as the institution 

participates as a nonprofit institution

(g) If an institution is initially certified as a nonprofit institution, or if it has undergone a change of 

ownership and seeks to convert to nonprofit status, the following conditions will apply to the institution 
Certification Procedures 10

upon initial certification or following the change in ownership, in addition to any other conditions that 

the Secretary may deem appropriate:

(1) The institution will be required to submit regular and timely reports on accreditor and state 

authorization agency actions and any new servicing agreements until the Department has accepted, 

reviewed and approved the institution's financial statements and compliance audits that cover two 

complete consecutive fiscal years following initial certification, or two complete fiscal years under its 

new ownership or until the Department approves the institution’s request to convert to nonprofit 

status, whichever is later; and

(2) The institution will be required to submit regular and timely reports on communications from the 

Internal Revenue Service or any state or foreign country related to tax-exempt or nonprofit status so 

long as the institution participates as a nonprofit institution.

(he) 

(1) A program participation agreement becomes effective on the date that the Secretary signs the 

agreement. 

(2) A new program participation agreement supersedes any prior program participation agreement 

between the Secretary and the institution. 

(if) 

(1) Except as provided in paragraphs (g) and (h) of this section, the Secretary terminates a program 

participation agreement through the proceedings in subpart G of this part. 

(2) An institution may terminate a program participation agreement. 

(3) If the Secretary or the institution terminates a program participation agreement under paragraph (f)

of this section, the Secretary establishes the termination date. 

(jg) An institution's program participation agreement automatically expires on the date that -

(1) The institution changes ownership that results in a change in control as determined by the Secretary 

under 34 CFR part 600; or 

(2) The institution's participation ends under the provisions of § 668.26(a) (1), (2), (4), or (7). 

(kh) An institution's program participation agreement no longer applies to or covers a location of the 

institution as of the date on which that location ceases to be a part of the participating institution.

§ 668.43 Institutional information.

(a) Institutional information that the institution must make readily available to enrolled and prospective 

students under this subpart includes, but is not limited to -

* * * 

(5) The academic program of the institution, including -

(i) The current degree programs and other educational and training programs; 
Certification Procedures 11

(ii) The instructional, laboratory, and other physical facilities which relate to the academic 

program; 

(iii) The institution's faculty and other instructional personnel; and

(iv) Any plans by the institution for improving the academic program of the institution, upon a 

determination by the institution that such a plan exists.; and

(v) If an educational program is designed to meet educational requirements for a specific 

professional license or certification that is required for employment in an occupation, or is 

advertised as meeting such requirements, information regarding whether completion of that 

program would be sufficient to meet licensure requirements in a State for that occupation, 

including -

(A) A list of all States for which the institution has determined that its curriculum meets 

the State educational requirements for licensure or certification; 

(B) A list of all States for which the institution has determined that its curriculum does 

not meet the State educational requirements for licensure or certification; and 

(C) A list of all States for which the institution has not made a determination that its 

curriculum meets the State educational requirements for licensure or certification;