Middlebury Handbook

Policy Statement
U.S. federal and state regulations require institutions of higher education to make a determination regarding the State in which a prospective or current student is located, which must be applied consistently to all students. 34 CFR 600.9(c)(2)(i). Further, institutions are required to have a policy to determine the location of a student for the purpose of sending required licensure disclosures. 34 CFR 668.43(c)(3)(ii)

Responsible Senior Administrator
EVP and Provost

Policy Contact
Associate Provost for Digital Learning

Effective Date
September 13, 2024

Next Review Date
Review yearly unless there is a change in regulation.

Definitions
Location: the state where a student is physically located when engaging in their education at Middlebury, which may be different than a student’s legal state of residence. Student location is determined at the time of census and is based on the mailing address submitted by the student at the time of the student’s initial enrollment.

Program: an academic program that leads to a degree or licensure

Prospective Student: any student who has contacted Middlebury requesting information concerning admissions to any program at Middlebury

State: any of the 50 states, the District of Columbia, or other U.S. jurisdictions (i.e. territories)

Student: for the purpose of this policy, any person enrolled or potentially enrolled in a Middlebury program, regardless of their location

Scope
This policy applies to all prospective and current students who are located in the U.S. and are enrolling in any Middlebury program, including but not limited to the following types of modalities:

• online programs
• online courses including online Language Schools
• hybrid courses
• face-to-face courses
• out-of-state learning placements including but not limited to internships, community services, fellowships, undergraduate research, or student teaching
• study-abroad programs

Policy
U.S. Federal Authorization and Professional Licensure Disclosure laws (34 CFR 600.9(c) and 34 CFR 688.43(c)) require Middlebury to determine student location in order to provide students with the appropriate authorization and licensing disclosures. Middlebury must regularly determine and report on the location of students who are participating in online or hybrid learning, or other out-of-state educational activities (such as internships or placements). Any educational activities outside of the state of Vermont are subject to the regulations of states and territories in which they occur. Professional licensure requirements also vary by location, and disclosures to students are required when a program does not meet the requirements within the student’s location. Further, NC-SARA policies require institutions to annually report student enrollment according to student location information as determined for the institution’s IPEDS enrollment report.

A student’s location is defined as the physical location of the student while enrolled and taking courses with Middlebury. Student location is determined at the time of census and is based on the mailing address submitted by the student at the time of the student’s initial enrollment.

It is the student’s responsibility to notify Middlebury if their location has changed. Student location will only be updated if a formal receipt of a change of location is made by the student, which should be made within 10 days of changing their location. Formal receipt is an update of a student's mailing address in the student information system. Online and out-of-state students are required to verify or update their location at the start of every term.

Data on distance education and student location will be aggregated and submitted to the National Council for State Authorization Reciprocity Agreements (NC-SARA) and the National Center for Education Statistics (Integrated Postsecondary Data System) each year.

Professional Licensure Programs

Per U.S. federal regulations, Middlebury is required to disclose the States for which the institution has determined its curriculum meets or does not meet the State educational requirements for licensure or certification. 34 CFR 668.14(b)(32) This information is published on the required academic programs’ websites.

Per U.S. federal regulations, Middlebury is required to make an individual written disclosure to prospective and current students if the student’s academic program does not meet the educational requirements for initial licensure/certification in the student’s State of location. 34 CFR 668.43(c) For prospective students, Middlebury must provide notice to that effect to the student prior to the student's enrollment at Middlebury in accordance with CFR 668.14(b)(32). For currently enrolled students, Middlebury must provide notice to that effect to the student within 14 calendar days of making such determination.

If Middlebury has not made a determination on whether or not the program leads to licensure in their location, the student will receive a disclosure to that effect prior to the first day of courses. If registration occurs after the first day of the term, the student will receive a disclosure prior to the drop date for the class.