Guidance Released on Student Activities Impacted by COVID-19

March 16, 2020 | Article

On March 5, 2020, the Department of Education issued a memo providing guidance for interruptions of study relating to coronavirus (COVID-19). The memo helps to address concerns expressed by higher education leaders on how they should comply with Title IV, Higher Education Act (HEA) policies for students whose activities are impacted by the COVID-19 either directly or indirectly.

Within the memo, there are five potential student and campus scenarios addressed and how the institution may address these scenarios and comply with Title IV, HEA requirements if there is an impact on the students or campus relating to the coronavirus.

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Potential Student and Campus Scenarios Impacted by COVID-19
Below are the five potential student and campus scenarios that were addressed in the memo:

  • A student was enrolled or was supposed to begin a travel-abroad experience and either the student has been called back to the U.S. or was never able to begin the travel abroad experience.
  • A student was enrolled in a program and met the requirements for full-time enrollment; however, due to the coronavirus, one or more classes—such as an internship, a clinical rotation, student teaching or fieldwork—have been cancelled and now the student has fallen below the 12 credit hour minimum and is no longer considered to be a full-time student.
  • A student is quarantined and misses class or a student is incapacitated due to the COVID-19.
  • A campus temporarily stops offering ground-based classes in order to prevent the spread of coronavirus.
  • A foreign school that serves U.S. students who participate in title IV programs temporarily suspends operations due to coronavirus.

Potential Solutions to Impacted Student Activities by COVID-19
The Department of Education’s primary goal is to work with educational institutions to find ways to accommodate students and allow them to continue their educational experience, despite the interruption of COVID-19.

Specifically, the memo focuses on the need to utilize online education to extend educational experiences for students. Online education can be a great aid for students who were recalled from a travel-abroad program or arrived in a foreign country only to have their program temporarily cancelled or suspended.

In order to do this, the Department of Education has offered the following flexibility:

  • Approval to offer distance education,>without the regular approval process of the Department of Education on a temporary basis. This flexibility only applies to a program during a payment period that overlaps the date of this electronic announcement or the following payment period.
  • Temporary waiver of distance education review requirements>for those educational institutions accommodating students whose enrollment is interrupted by COVID-19. This temporary waiver is limited to distance learning opportunities developed for serving students who were already in attendance, but whose attendance was interrupted by COVID-19.
  • Temporary consortium agreements with other institutions>where students can complete courses at a different institution but earn credit at their home institution.
  • Offer a non-standard term> for students whose travel abroad programs or experiential learning opportunities were cancelled after the semester began. This option is offered so that those students are still able to complete the term.

What to Do in the Wake of COVID-19
The ideas and solutions outlined are a brief overview of the Department of Education’s memo in relation to COVID-19. To see the full details of the announcement, make sure to read the memo in its entirety here.

For any decisions taken by the institution, it should be well documented, including those situations described in the Department of Education memo. Additional information can be found at the Department of Education’s Coronavirus website.

COVID-19’s impact on educational institutions is complicated.

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