How Do We Treat Our Students Who Have Been Dropped From a Clinical Program Due To Coronavirus?

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This guidance is not award-year-specific and applies across award years.

This AskRegs Knowledgebase Q&A was updated on April 12, 2023 to note that the general COVID-19 national emergency ended on April 10, 2023, while the separate public health emergency ends on May 11, 2023. With the introduction of two separate emergency end dates, it is now unclear which date is to be used for the expiration of the COVID-19 flexibility/waiver discussed below. See AskRegs Q&A, When Do the Various Title IV COVID-19 Flexibilities and Waivers End? 

Scenario: The students were enrolled and attending the clinical; however the hospital decided to suspend all clinicals/externships due to the COVID-19 outbreak.

Answer: In instances when coursework is suspended, including clinicals and externships, the U.S. Department of Education (ED) permits clock-hour and credit-hour schools to place these students on a Title IV-approved LOA instead of withdrawing them and performing return of Title IV funds (R2T4) calculations. This is true even if the student requests the LOA after the date the LOA has begun. In such instances, the institution may retain those Title IV funds to apply when the student resumes enrollment. If the school does not place these students on a Title IV-approved LOA, the student is a withdrawal and an R2T4 calculation is required. The student is also reported as a withdrawal via NSLDS Enrollment Reporting.

Per the March 5, 2020 Electronic Announcement, "Normally, institutions are not permitted to put students on a leave of absence during the suspension of coursework, including clinicals or internships/externships; however, if the coursework suspension results from COVID-19, in this limited circumstance the Department will permit the institution to put the student on an approved leave of absence until the institution can resume coursework or can find another placement for the student." The attachment to the announcement confirms that this applies equally to clock-hour programs, and goes on to state, "Note that this guidance only applies if there is a reasonable expectation that the institution will be able to resume coursework and/or find a placement for the student. If the institution cannot resume coursework or find a placement for a student in this circumstance within 180 days, or if the number of days in all of the student’s approved leaves of absence in a calendar period has exceeded 180 days, the student must be considered withdrawn and an R2T4 calculation performed."

Since the March 5 announcement, there have been several changes to what is now considered a Title IV-approved LOA under COVID-19 guidance, including an extension of the 180 day maximum length of an LOA referenced in the March 5th guidance. Be sure to review AskRegs Q&A, Must It Be a Title IV-Approved Leave Of Absence To Qualify Under the COVID-19 Guidance?, when determining whether your student is on a revised Title IV-approved LOA or is a withdrawal for Title IV purposes.


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