December 2020

ACCET is closely monitoring the situation regarding the coronavirus (COVID-19) and providing our member institutions additional guidance as it becomes available. This ACCET updated guidance (dated December 14, 2020) is to notify ACCET institutions of: (1) extensions to the time-period for temporary flexibilities due to COVID-19, and (2) additional temporary flexibilities approved by the ACCET Commission at its December 2020 meeting.  It is important to note the following:

• At its December meeting (December 7-10, 2020), the ACCET Commission approved temporary flexibilities identified in this notice for “the duration of the national COVID-19 emergency” to be reassessed by the Commission at its April 2021 meeting (April 5-7, 2021). Further, the ACCET Commission approved additional temporary flexibilities regarding leaves of absence and 2020 completion and placement statistics, which are highlighted in italics below.
• In approving temporary flexibilities, ACCET is following the guidance of the U.S. Department of Education and the Student Exchange Visitors Program (SEVP), including the period for temporary flexibilities due to COVID-19.
• On December 11, 2020, the U.S. Department of Education issued additional guidance extending temporary flexibilities for “the duration of the national emergency declaration,” unless otherwise specified. Although SEVP has not issued updated guidance, on December 9, 2020, “NAFSA confirmed with SEVP that guidance for the Spring 2021 term will be the same as for Fall 2020.”
• Additionally, the U.S. Department of Education announced extended federal student loan flexibilities. Currently, the 0% student loan interest rate and suspension of payments on federal student loans owned by the Department of Education (ED) are set to continue through January 31, 2021.
• Note that when federal, state, local, and/or accreditation requirements conflict, institutions are required to follow whichever requirement is most stringent.

Temporary flexibilities approved by the ACCET Commission are identified below, including additional temporary flexibilities approved at the December 2020 Commission meeting, as highlighted in italics. 

Temporary Flexibilities:  ACCET guidance provides certain flexibilities for institutions that are working to help students complete the term in which they are currently enrolled and identifies options available to institutions so that they can continue to serve students for the “duration of the national COVID-19 emergency” to be reassessed by the ACCET Commission at its April 2021 meeting, including:

• Temporary closure.
• Temporary distance learning (IDL) delivery.
• Change in student enrollment status (e.g. full-time to part-time status) (This option is not available to IEPs).
• Consortium agreements (This option is not available to IEPs).
• Temporary change of location (This option is only available to IEPs).

Temporary Distance Education: The temporary flexibilities authorized to ACCET institutions during the COVID-19 threat are finite. Currently, institutions are permitted (without program approval) to temporarily offer distance learning (IDL) to new students through “the duration of the national COVID-19 emergency” to be reassessed by the ACCET Commission at its April 2021 meeting, with the following exception. The Student Exchange Visitors Program (SEVP) does not permit the enrollment of new F and M students in distance education.

Externships: Institutions will be permitted the temporary flexibility (beginning March 5, 2020) of offering students whose scheduled internship/externship is disrupted due to the national COVID-19 emergency each student’s choice to either:

1. Complete a rescheduled externship/internship, which may require the student to take a leave of absence; or
2. Complete, in lieu of internship/externship, a capstone course comparable in length (clock hours or credit hours) to the internship/externship, unless prohibited by any applicable licensing boards and/or other approval or certifying authorities.

Labs:  Institutions will be permitted the temporary flexibility (beginning March 5, 2020) of offering students, whose scheduled labs are disrupted due to the national COVID-19 emergency, each student’s choice to either: 

1. Complete rescheduled labs, which may require students to take a leave of absence;
2. Complete simulated labs that: (a) provide synchronous (real time) sharing of hands-on practice using video conferencing, and (b) assess students’ skills based on observed levels of performance during lab time. Note that this option is not permissible if prohibited by any applicable licensing boards and/or other approval or certifying authorities; or
3. Complete didactic classes, comparable in length (clock hours or credit hours) to the labs missed due to COVID-19, on the condition that the institution schedules make-up labs in the future to provide students the opportunity to subsequently complete labs necessary for students to develop and practice their hands-on skills. Note that this option is not permissible if prohibited by any applicable licensing boards and/or other approval or certifying authorities.

Verification of High School (or Equivalent) Completion Status: Where an institution is unable to obtain documentation of an applicant’s high school completion or equivalency, an institution will be permitted the temporary flexibility to accept a signed and dated attestation from an applicant. The applicant must attest to his or her high school completion including the approximate date of completion in lieu of the applicant’s official high school diploma, official transcript, or high school equivalency certificate during the national COVID-19 emergency period. Note that this temporary flexibility is not permissible if prohibited by any applicable state and/or other approval or certifying authorities.

Leaves of Absence (LOA):  Institutions will be permitted the following temporary flexibilities during the national COVID-19 emergency period (beginning March 27, 2020) relative to leaves of absence, including:

1. Waiving the requirement that: (a) the institution must approve a written and signed leave of absence request by the student prior to the leave of absence and (b) the student returning from a leave of absence (LOA) must resume at the same point in his/her program that the student began the LOA.
2. Establishing, even on a temporary basis, a formal written leave of absence policy consistent with any state, federal, local, and accreditation requirements, if the institution previously did not have a formal written policy.
3. Due to COVID-19, institutions will be permitted expanded temporary flexibility relative to leaves of absence. Institutions may grant a leave of absence for up to 365 days within a twelve-month period during the national COVID-19 emergency period beginning March 27, 2020.
4. For institutions that are temporarily closed due to COVID-19, the institutions will be permitted to place students on an “administrative leave of absence” for the period of the institutions closure during the national COVID-19 emergency period.

Satisfactory Academic Progress (SAP): Institutions will be permitted the following temporary flexibilities during the national COVID-19 emergency period (beginning March 27, 2020) relative to satisfactory academic progress (SAP):

1. An institution may exclude from the quantitative component (pace measurement) of satisfactory academic progress (SAP) attempted credits/hours a student was unable to complete as a result of the COVID-19 national emergency.
2. It is not necessary for a student to file a SAP appeal for an institution to exercise the flexibility identified in item #1. However, to exclude attempted credits/hours from SAP, an institution must have reasonably determined that the student’s failure to complete those credits/hours was the result of a COVID-19 related circumstance.  Allowable circumstances include but are not limited to: (a) illness of the student or family member, (b) need to become a caregiver or first responder, (c) economic hardship, (d) added work hours, (e) loss of childcare, (f) inability to continue with classes via distance education, (g) inability to access wi-fi due to closed facilities. If an institution temporarily ceases operations during a period of enrollment, attempted credits for all affected students (specific to that enrollment period) may be excluded.
3. Regarding the effect of excluding attempted credits on maximum timeframe, SAP regulations require that the pace at which students progresses through the program ensures completion of that program within the maximum timeframe (150% of program length). However, if credits/hours the student attempted, but was unable to complete, are excluded due to a COVID-19 related circumstance, the credits/hours will be effectively excluded from the maximum timeframe as well as the measurement of pace.

Completion and Placement Statistics:

• Institutions will report 2020 completion and placement for informational purposes during the COVID-19 emergency. The U.S. Department of Education defines the emergency period as continuing for “the duration of the national emergency declaration,” unless otherwise specified.

• Institutions will not be assessed for below benchmark rates for completion and/or placement in 2020 during the COVID-19 emergency unless there are extraordinary circumstances. However, institutions are expected to continue to document their completion and placement processes and provide student services, consistent with policies and procedures of ACCET, the institution, and any pertinent regulatory bodies.

• Institutions will be evaluated for completion and placement reported (Document 28.1s) for the period of 2019 (January 1 – September 30) or 2019 (January 1 – December 31, 2019), if an institution prefers, a period before the COVID-19 emergency.

Completion Flexibility for Calendar Year 2020:  For the Calendar Year 2020, the Commission will consider completion waivers for students who are unable to complete their program due to circumstances related to the COVID-19 pandemic. Allowable circumstances, include, but are not limited to:

• Illness of the student or family member;
• Need to become a caregiver or first responder;
• Economic hardship;
• Added work hours;
• Homeschooling or child/dependent care issues;
• Inability to continue with classes via distance education; and
• Inability to access wi-fi due to closed facilities.

COVID-19 waivers must be documented including the student’s signature, date, and notification of a specific reason.  Waivers that bring the percentage above 10% will result in adjusted waiver and completion rates and will be reviewed by the Commission.

Placement Flexibility for Calendar 2020:  For the Calendar Year 2020, the Commission will consider placement waivers for students who are waiving placement assistance due to circumstances related to the COVID-19 pandemic. Allowable circumstances include, but are not limited to:

• Illness of the student or family member;
• Need to become a caregiver or first responder;
• Economic hardship;
• Added work hours;
• Homeschooling or child/dependent care issues; or
• Inability to continue with classes via distance education; and
• Inability to access wi-fi due to closed facilities

COVID-19 Waivers must be documented, including the student’s signature, date, and notification of a specific reason.  Waivers that bring the percentage above 15% will result in adjusted waiver and completion rates and will be reviewed by the Commission.

Depending on the duration and severity of COVID-19, the Commission may decide, in future, to review its completion and placement policy such as completion/placement waivers and/or benchmarks.

April 2021 Review Cycle:

• During the April 2021 visit cycle, virtual accreditation visits will be conducted in lieu of on-site evaluation visits.
• As required by the U.S. Department of Education, follow-up on-site visits will be scheduled in a timeframe that is reasonably practicable to institutions that have virtual visits for purposes of accreditation, reaccreditation, and/or substantive changes. At a minimum, these on-site visits will be one-day/one-person visits to verify: (a) the facility, (b) student satisfaction, and (c) compliance with any standards with a rating of “1” or “2” in the virtual visit team report.
• Note that the virtual visit fee will include the cost of a 1-day/1-person follow-up on-site visit, required by the U.S. Department of Education. There will not be an additional fee for the required on-site verification visits, unless the Commission directs an expanded on-site verification visit that exceeds the typical 1-day/1-person visit.

ACCET will continue to provide information to ACCET institutions as warranted.  Institutions are also advised to frequently check the websites of the U.S. Department of Education, the Center for Disease Control (CDC), the U.S. Department of Health and Human Services (DHHS), and other authorities for updated information including:

• https://www.ed.gov/coronavirus
• https://www.ICE.gov/COVID19
• https://www.cdc.gov/coronavirus/2019-ncov/index.html
• http://who.int/health-topics/coronavirus