Trending AskRegs Q&A: What Considerations Are Needed When Changing Our Clock-Hour Program To an Online Format Due To Coronavirus?

What Considerations Are Needed When Changing Our Clock-Hour Program To an Online Format Due To Coronavirus?

Scenario:  We have a clock-hour program that we are considering moving to an online format in response to the COVID-19 outbreak. How do we implement this program and remain in Title IV compliance?

Answer: According to the U.S Department of Education (ED):

"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."

The above guidance has been excerpted from the COVID-19 FAQs document attached to ED's March 5, 2020 Electronic Announcement.

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Publication Date: 3/20/2020

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