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Meeting of the Board of Regents | March 2010

Monday, March 1, 2010 - 11:10pm

sed seal                                                                                                 




The Professional Practice Committee


Frank Muñoz



Online Learning and the Licensed Professions


February 23, 2010


Goals 2, 3, and 4




Issue for Discussion

The Professional Practice Committee will discuss the development and current status of online learning in professional education programs that lead to licensure in the 48 professions. The discussion will build upon the 2004 Statewide Plan for Higher Education and focus on public protection to ensure that online learning programs that prepare students for entry into the Title VIII professions provide the necessary education content, including the supervised clinical internships and practica that comprise part of many educational programs.


Reason(s) for Consideration


              For discussion.

Proposed Handling

This matter will come before the Professional Practice Committee at its March meeting for discussion. 

Procedural History

The Board of Regents addressed the use of online learning and distance education in higher education in the 2004 Statewide Plan for Higher Education.  Concerning distance education, the Regents said:

Looking into the future, distance learning has the potential to address [the Regents priority of higher education quality] as well as other Regents priorities.  It has the capability to:


  • provide access to virtually anyone in this State;
  • enable residents to pursue educational opportunities within their family and workforce obligations;
  • provide specialized study and training to professionals and communities where experts are not readily available; and
  • assist licensed professionals to fulfill mandatory continuing education and competency requirements to better serve the public.


The Regents statement was based on the Department’s work in the area of distance education, including discussion in June and September 2000 of the recommendations of the Department’s Task Force on Distance Education.

At your March 2010 Higher Education Committee meeting, staff will discuss the development and current status of online learning and distance education in higher education in New York State, including Institutional Capability Reviews and examples of good practices by public, independent, and proprietary higher education institutions. However, the Board of Regents has not addressed unique online learning issues related to professional education for licensure in the 48 professions under Title VIII of the Education Law. This discussion will supplement what is discussed in the Higher Education Committee, focusing on the current use of online learning in licensure-qualifying programs and the unique challenges faced by professional education.

Background Information

The Board of Regents authorizes colleges and universities to award degrees in New York. The Professional Education Program Review (PEPR) unit in the Office of the Professions, in partnership with the State Board offices, is responsible for the review and registration of programs that lead to licensure in the professions. PEPR receives and reviews 300 applications for program registration each year and ensures that a program meets the general registration requirements in Parts 50 and 52 of the Commissioner’s Regulations and any program-specific requirements in Part 52 before registering the program. A student who graduates from a program registered as licensure-qualifying will not require individual evaluation of his or her education, expediting the application for licensure.

Online Learning. PEPR uses the definition established by the Office of Higher Education to designate a program as offered in a distance-learning format when more than 50 percent of the program is offered through distance education, including video-links to remote sites and internet-based coursework completed independently by students. Currently, very few professional education programs are registered in a distance-education format. There are nearly 1,800 programs registered as leading to licensure in New York and only 30 programs (1.7 percent) are registered as distance-education programs. The most significant use of distance education in professional education is for those programs leading to licensure as a nurse-practitioner (14).

Table 1.  Distance Learning Programs Registered in the Professions


Total Programs


Distance Learning Programs*

% Distance Learning

Schools with Distance Learning

Certified Dental Assisting




HVCC, Monroe CC, Buffalo EOC

Certified Public Accountant (150)




SUNY Utica Rome, Syracuse, Utica College

Clinical Laboratory Technician




SUNY Broome CC





SUNY Oneonta





SUNY Stony Brook

Registered Nursing




SUNY Stony Brook, Health Science Center Syracuse

Nurse Practitioner




SUNY Stony Brook, Buffalo, Health Science Center Syracuse

Upper Division, Non-licensure Nursing




Mercy, SUNY Delhi, Canton, Buffalo, ESC, Stony Brook

Respiratory Therapist




SUNY Health Science Center Syracuse

* Programs with 50% or more in distance learning format

Although a relatively small number of programs leading to licensure are registered as distance-learning programs, it is likely that many more programs use distance learning for some portion of the education program. For instance, students may use Internet-based technology to complete reading assignments or participate in discussions to augment classroom instruction, or a college may use videoconference technology for real-time participation in classroom instruction by students in rural locations. The basic challenges and best practices for general education programs are discussed thoroughly in the March 2010 item prepared for the Higher Education Committee.

Accreditation.  PEPR reviews and registers programs that are offered by schools in New York as leading to licensure in the 48 professions. However, individuals seeking licensure in New York may have attended a college or university outside of New York. In a majority of the professions, the Office of the Professions relies on regional accreditation and specialty accreditation to determine if a program outside of New York is acceptable for licensure. These accrediting bodies perform functions similar to OHE and PEPR. The regional accrediting bodies determine that the institution has the capability to provide the education to students, and the specialty accrediting body will verify that the program offers course work required for entry into the profession. The accrediting bodies typically do not differentiate between traditional and online learning, so that, in those professions in which OP relies on accrediting bodies, it accepts verification from accredited programs without individual evaluation. A 2002 study by the Commission for Higher Education Accreditation (CHEA) found that professional accreditation standards were largely based on competency or outcomes, so that it was not necessary to make extensive revisions in the accreditation standards as online learning was typically viewed as another format for delivering education content.

Issues to Consider in Online Learning

              The growth of the Internet as a way to deliver goods and services also affects the traditional concept of geographic boundaries and the Board of Regents’ oversight of professional education programs. Education programs in New York and across the nation are increasingly using technology to provide online learning and to increase access to education. However, there are issues to be considered in the development of online learning programs for the licensed professions.

Clinical Internship and Practica. The use of online learning and training for the Title VIII professions can raise particular issues when students must complete a hands-on laboratory or a supervised practicum, internship or field experience in the educational program. While technology can provide real-life simulation for various skills, these simulations may not reflect the interpersonal interactions that are critical for the development of the knowledge, skills, and abilities needed for the practice of a profession. On the other hand, a program that utilizes online learning can bring together students in many locations with an instructor to provide an enriched learning experience.

An online learning or distance education program may extend access to didactic coursework to students in remote areas, but offering clinical experience in an online program presents other challenges. The program should ensure that students complete appropriate, supervised clinical internships as part of the registered program. Listed below are the professions which require practical educational experiences, such as internships, practica or laboratories, as part of the education program.

Table 2.  Education Programs with Clinical or Internship Requirement

Licensed Creative Arts Therapy

Dental Hygiene

Respiratory Therapy

Licensed Clinical Social Work

Dental Assisting

Respiratory Therapy Technician

Licensed Master Social Work

Registered Nurse


Licensed Marriage & Family Therapy

Nurse Practitioner


Licensed Mental Health Counseling

Massage Therapy

Athletic Training

Licensed Psychoanalysis


Ophthalmic Dispensing


Clinical Laboratory Technology


Clinical Laboratory Technician



Physical Therapy

Physical Therapist Assistant



Physician Assistant

Specialist Assistant

Public Protection. When PEPR reviews and registers an education program in New York, it ensures the school has established sufficient internship and practicum sites. The factors that are considered in a traditional program would also apply for the review of online learning programs, including:


  • Collaboration agreement between education program and institution offering clinical supervision to students;


  • Supervision by individuals who are appropriately licensed and registered or qualified to practice and supervise the profession, as defined in the laws and regulations for the particular profession; and


  • Appropriate identification of students who are providing services to the public.


These factors are relevant whether a program is in a traditional or distance education format, although the challenges to the educational institution may be different when providing education in remote locations. The use of online learning does not reduce the school’s role in assuring the appropriateness of the setting, qualifications of the supervisor, and the students’ satisfactory completion of the internship.

              Access to Education. Online learning can increase access to education by providing flexibility in scheduling classes and completing assignments. A resident of rural New York or one with family and job commitments may consider an online learning program as the pathway to education, including entry to one of the licensed professions. Online learning also provides licensees access to advanced training in the professions and continuing education activities that are necessary to maintain competence.

Impact of Online and Distance Learning. Non-traditional educational formats present challenges in determining the effect of new programs on existing educational programs that lead to licensure. Traditionally, when a new degree program is submitted for registration, PEPR has canvassed schools in the surrounding area to determine whether the new program may have an adverse effect on existing programs. When a program is offered through online or other technology, it may affect educational programs and the availability of supervised internships and practica in far-reaching parts of New York. These challenges should be considered in discussions with stakeholders as the Department addresses the growth of online learning and distance education in the preparation of individuals who will enter the 48 professions under Title VIII.

Limitations on Online Learning. While online learning can provide flexibility and increased access to education, there may be limitations such as activities that cannot be completed online or through simulations, from hands-on laboratories in the design professions through direct patient interaction in the health professions. Leaders within the Office of the Professions should continue to represent the Board of Regents and the Department in discussions with the accreditation bodies for the education programs in the licensed professions.

PEPR Review and Registration. Today, PEPR and the State Boards for the Professions review and register only programs that are offered by schools physically operating in New York. As distance learning grows and students in New York seek to enroll in online programs, which may be based in other states, it may be appropriate for the Department to review its procedures to ensure that quality standards are met and students receive assurance that completion of the program could lead to licensure in the professions. This will require increased activity by OP leaders, through participation with national accrediting and licensing bodies for the professions. New York can and should play a leadership role to ensure public protection and increase access to education.

Next Steps

              The purpose of this presentation is to provide an overview and snapshot of online learning and distance education in the licensed professions. We will continue to explore and address these issues to ensure that programs completed by students seeking licensure will meet the standards established in law so that they may take the first step toward licensure in the professions.