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COE: COVID-19 ALERT 1: Temporary Approval for Distance Education Instruction (March 31, 2020)

News Mar 31


Temporary Approval for Distance Education Instruction

(March 31, 2020)

Institutions considering the use of distance education to deliver instruction to students during this period must comply with the notice published by the Financial Student Aid division of the U.S. DOE. (USDE Notice Revised March 20, 2020).

All notices and documents that pertain to the COVID-19 outbreak are posted on the Council’s website ( on the home page under ‘New and Events’.

Critical Points Regarding Temporary Distance Education Approval 

  • Council approval is required if you choose to employ this method.
  • Institutions must confirm the requirements of all applicable state governing bodies for use of distance education and be aware of restrictions that apply (if any).
  • Temporary approval to offer instruction via distance education remains valid for the period of time allowed under guidance provided by the U.S. Department of Education in response to the COVID-19 outbreak.
  • Temporary approval to offer instruction via distance education includes students enrolling for instruction in payment periods that begin on or before June 1, 2020.
  • The U.S. Department of Education cites specific methods regarding the delivery of instruction via distance education in its original notice dated March 5, 2020. It is imperative that Council approval is secured if any of the methods cited below are being used to deliver instruction. (Bold font and underline has been added to emphasize critical terms and phrases.):

We want to make clear to institutions that for Title IV, HEA purposes, distance learning does not require the use of sophisticated learning management systems or online platforms, though accreditors may have additional standards included in their review of distance learning programs. We are, however, permitting accreditors to waive those standards for schools implementing distance learning programs solely for the purpose of allowing currently enrolled students to complete a term that is interrupted by COVID-19 closures. To meet the Department’s requirements for providing distance education, an institution must communicate to students through one of several types of technology – including email – described under 34 CFR § 600.2, and instructors must initiate substantive communication with students, either individually or collectively, on a regular basis. In other words, an instructor could use email to provide instructional materials to students enrolled in his or her class, use chat features to communicate with students, set up conference calls to facilitate group conversations, engage in email exchanges or require students to submit work electronically that the instructor will evaluate.

The application and information sheet is available on the COE website (under News and Events on the homepage) for institutions seeking temporary approval to employ distance ed delivery. Council staff have been processing these applications and returning decision letters very rapidly to help institutions minimize delays implementing this method.

Submit completed applications to Marcia Cox via email ([email protected]). processing.

USDE Notice – March 5, 2020 (Addendum added March 20, 2020_see Attachments at bottom of page)

USDE Notice – Addendum that was added March 20, 2020 (COVID-19 FAQs, 4 Pages)

COE Recommendations Regarding COVID-19 (30 March 2020)

COE Temporary Distance Education application