This guidance is not award-year-specific and applies across award years.
Scenario: We resumed our regular online courses on schedule after spring break ended. Many of our traditional “brick and mortar” residential students also have enrolled in these online classes. However, due to COVID-19, the residential classes were delayed by a week to give our faculty time to move the residential classes online. Did we actually extend our spring break since we delayed the brick and mortar classes by a week? We have no plans to add days onto the end of the semester.
Answer: According to guidance NASFAA has received from the U.S. Department of Education (ED), it depends on whether it is truly a hybrid program offering both online and residential classes within the same program, or if there are two different programs. This determination is left to the reasonable discretion of the institution.
Hybrid Programs: Per ED, schools generally treat online programs as separate programs with little cross-enrollment. However, ED does recognize that it is possible for schools to offer truly hybrid programs consisting of both online courses and residential courses within a single program. If so, class enrollment patterns should support the existence of a single hybrid program.
If the program in the scenario is truly a single hybrid program, classes would be considered to have continued across-the-board with no extended break and no reduction in the length of the academic year. No further action is required.
Separate Programs: If the programs are separate programs, then the academic calendars for the online and residential programs should be looked at separately. If the residential program is a separate program with a separate academic calendar, then the academic year for that program has been reduced. If the extended break results in an academic year of less than 30 weeks of instructional time, then you must obtain ED's approval. For more information, including the process for requesting ED approval, refer to AskRegs Knowledgebase Q&A, What Factors Do We Consider When Deciding To Extend a Scheduled Break Due To Coronavirus?
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.
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