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COVID-19 Implications: Distance Ed, Approvals and Other Considerations

Strategize. At a time when quick turn-around is in high demand, where “time is of the essence,” it is easy to make a decision that has not been fully thought out or jump into an agreement that perhaps your school would not get into under different circumstances.

The recently declared “National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak,” Proclamation 9994 of March 13, 2020[1] has paved the way for a new era; one in which terminologies such as “social distancing,” “contactless delivery,” and “safer-at-home” are becoming the new norm.

In our current day, where academic communities are faced with making difficult decisions, we are now faced with yet another! One which unexpectedly took its place as #1 at the top of the constantly growing list of priorities is the restructuring of our academic delivery system to accommodate orders being executed by state and local officials throughout.

Schools around the world are having to adapt to and change from offering a face-to-face on-site delivery of classes in what is commonly referred to as the brick and mortar format to a virtual learning environment or distance education using communication mediums like email, chat, video conferencing, internal management platforms, or by partnering with companies that have already developed robust learning management systems (LMS).

At a time when quick turn-around is in high demand, where “time is of the essence,” it is easy to make a decision that has not been fully thought out or jump into an agreement that perhaps your school would not get into under different circumstances. Moving forward with academic changes is a huge decision that should not be taken lightly. An in-depth analysis should be conducted to identify whether or not to use systems that are already available internally or if a new platform should be acquired.

As such, it is important to remember that recognizing the needs of your institution and students is key when moving forward with the selection of a learning management system that will assist in the transition of offering your academic programs in a virtual environment.

The administrative team at your school should map out the courses offered and identify all of the items that directly impact the decision to move forward virtually. Things like the academic requirements of each program, including the practical and theoretical components involved, certification requirements such as licensure limitations or expectations, state and accreditation requirements, maintaining or enhancing the school’s security safeguard measures that protect your students’ privacy and more.

Knowing these items will help your administrative team identify which programs or course offerings your school may be able to transition to the virtual environment, versus those that must remain in the brick and mortar format. These considerations will also assist those in the decision-making process when identifying which learning management system is best suited for your school.

Prior to moving forward with programs offered via distance education, it is recommended that your administrative team evaluate the electronic security safeguards currently in place at your school to ensure that student privacy is protected in accordance with the FERPA and Gramm-Leach-Bliley Acts. Based on the results of your evaluation, and if needed, your institution should enhance and strengthen the areas of such safeguards to accommodate for distance education, since transitioning to a virtual platform does not eliminate the guidelines set forth by such Acts. In fact, those guidelines should be considered when your school is conducting the analysis to determine if internal systems can be used or if external resources should be obtained.

To assist schools with their restructuring of the academic delivery systems offered, the U.S. Department of Education (ED) announced in the Electronic Announcements dated March 5, 2020 and April 3, 2020.[2] that an allowance is being extended for “institutions to use online technologies … without going through the regular approval process of the Department in the event that an institution is otherwise required to seek Departmental approval for the use or expansion of distance learning programs.”

Before moving forward with ED’s allowance, schools must obtain prior approval to offer temporary distance education from their state and accrediting agencies. While certain flexibilities are afforded as a direct result of Proclamation 9994 and through the aforementioned announcements, it is important to know that such flexibility is temporary and “applies only to payment periods that overlap with the Department’s March 5, 2020 guidance or that begin on or between March 5 and June 1, 2020.”[3]

Should your school decide to continue offering programs through distance education after the official National Emergency has ended, the school will need to obtain approval to do so from ED using their regular approval process.

Schools should continuously monitor the governing bodies respectively for updates on the latest information of temporary adjustments that may impact the academic community as our society continues to navigate the uncharted waters of the COVID-19 outbreak.

[1] Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak

[2] Guidance for interruptions related to Coronavirus (COVID19)

[3] UPDATED Guidance for interruptions of study related to Coronavirus (COVID19)

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