Can We Assign an Incomplete Grade Instead Of a Leave Of Absence For Clinicals Interrupted By COVID-19?

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This AskRegs Knowledgebase Q&A was updated on December 21, 2020 to reflect the December 11, 2020 Federal Register which extended previous flexibilities for Title IV-approved leaves of absence (LOA). The following COVID-19 flexibilities now apply through the end of the payment period that begins after the date on which the federally declared qualifying emergency related to COVID-19 is rescinded.

Scenario: We have students who were on nursing clinicals (externships) that they cannot complete at this time due to COVID-19. Some of these students have term-based online coursework they can complete outside of their clinicals. Our instructors want to give them incomplete (I) grades instead of placing them on LOAs.

Answer: It depends and is generally a matter of institutional academic purview. However, there are considerations. Remember that the intent of an incomplete grade is that it:

1) Is usually assigned at the end of a term (not the middle of a term) at a term-based school when the student and professor agree the student is unable to complete the requirements of an individual course and needs more time to complete the work;

2) There must be the expectation that the student will eventually complete the required coursework within a reasonable and defined period of time to receive credit and a passing grade (reasonable in this context is defined by the school and not the U.S. Department of Education (ED);

3) The assumption is that the student is continuing academic coursework while in the incomplete status;

4) Your SAP policy has to address how you treat incompletes; and

5) A student who is awarded the grade of incomplete in all of his or her classes is not considered a student on a Title IV-approved LOA unless the LOA meets the criteria in 34 CFR 668.22(d), as amended by COVID-19 guidance. See AskRegs Q&A, Must It Be a Title IV-Approved Leave Of Absence To Qualify Under the COVID-19 Guidance?

Keep these considerations in mind as you make these determinations. If the student’s clinical has been suspended and the student cannot continue the coursework or field work, the student is not really continuing academic coursework during this period, so the student is either put on an LOA or is a withdrawal under the March 5, 2020 Electronic Announcement guidance. If the student is allowed to complete other coursework while the clinical has been suspended, the student is not a withdrawal nor on an LOA. If the student is then unable to complete the required coursework at the end of the term, an incomplete may be appropriate (instead of an LOA). That’s the school’s decision. Reference Volume 5, Chapter 1 of the FSA Handbook.

Note 1: Incompletes cannot apply in clock-hour and nonterm credit-hour programs because academic progression is measured in the actual completion of hours and weeks of instructional time.

Note 2: This guidance applies beyond clinicals and externships. It applies to all term-based programs.

Note 3: In the FAQs attached to the March 5, 2020 Electronic Announcement, ED provided the guidance below for schools with clock-hour programs where students are not able to complete clinicals:

“Normally, institutions are not permitted to put students on a leave of absence while coursework, including clinicals or internships/externships, is suspended. However, if a student’s coursework is cancelled as a result of COVID-19 and the student is enrolled in a clock hour program, 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. This will prevent the institution from considering the student to be withdrawn and performing an R2T4 calculation that will need to be reversed.

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.”

Per the December 11, 2020 Federal Register, this clock-hour flexibility now applies through the end of the payment period that begins after the date on which the federally declared qualifying emergency related to COVID-19 is rescinded.

Note 4: In addition, per the August 21, 2020 Electronic Announcement, "The Department is extending the maximum duration of an LOA from 180 days to also include the number of additional days remaining in the calendar year. This flexibility includes students who are already on an LOA approved since the original flexibility was granted."

Note 5: Any additional questions on this topic must be directed to your ED School Participation Division via the [email protected] mailbox.

Note 6: This AskRegs Knowledgebase Q&A was previously updated on August 24, 2020 to reflect the August 21, 2020 Electronic Announcement extension of the timeframes for the March 5, 2020 Electronic Announcement guidance, as well as to the maximum duration of a Title IV-approved leave of absence.

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.