Is There Specific Guidance For Clock-Hour Programs and Students Affected By the Coronavirus?

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This AskRegs Knowledgebase Q&A was updated on January 20, 2021 to reflect the January 15 Electronic Announcement  and December 11, 2020 Federal Register which extends the flexibility related to Title IV-approved leaves of absence (LOAs) through the end of the first payment period that begins after the end date for the federally-declared qualifying emergency related to COVID-19. Institutions have the option to early implement provisions in the September 2, 2020 Federal Register which, if the licensure body allows, clock-hour programs may be offered via distance education synchronously or asynchronously. Otherwise, accrediting agencies must meet the requirements of 34 CFR 602.21(c). All other flexibilities still apply only through the end of the payment period during which the qualifying emergency ends. 

Generally, no. According to guidance NASFAA has received from the U.S Department of Education (ED), unless otherwise indicated, the flexibilities issued in the March 5, 2020 Electronic Announcement, the April 3, 2020 Electronic Announcement, the May 15, 2020 Electronic Announcement  and the August 21, 2020 Electronic Announcement apply across all institutions, including schools with clock-hour programs. ED does not intend to issue separate guidance that is specifically related to clock-hour programs. However, ED did emphasize the following considerations. NASFAA provided clarification and additional information wherever possible.

Nonterm Payment Periods In the Common Origination and Disbursement (COD) System:

Withdrawals and Return of Title IV Funds (R2T4):

Packaging Rules:

Moving Clock-Hour Programs To Online Formats: When a school moves a clock-hour program to an online format in response to the COVID-19 outbreak, the school should consider the following guidance from the FAQs attached to the March 5, 2020 Electronic Announcement:

"An institution that offers a clock hour program in a distance education format must ensure that each clock hour of instruction is supervised by qualified institutional personnel. In most cases, synchronous instruction through distance education, where students are actively engaged with an instructor in real-time discussion, would provide an adequate platform for the instructor to supervise students in clock hour programs.

However, an institution that offers asynchronous instruction in a clock-hour program must maintain an online learning platform or another system for monitoring each student’s academic engagement to ensure that students are academically engaged in at least 50 minutes for each hour that is recorded as a clock hour attended by the student. In this circumstance, an instructor can complete a student’s timesheet to include clock hours earned in a distance education format, but the hours must be based on data or the instructor’s own knowledge that the student was academically engaged for at least 50 minutes out of each clock hour that is recorded.

Institutions must ensure that any clock hour offered through distance education meets all applicable requirements set by accrediting agencies and States and fulfills applicable educational prerequisites for State licensure."

​​​​​​​Additional Information: As NASFAA receives additional guidance specific to clock-hour programs from ED, we will update this AskRegs Q&A and post it in Today's News. Schools with specific questions on this topic should continue to submit them to ED at [email protected] or to NASFAA via the AskRegs Knowledgebase.

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.