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Jen Kim

Colleges looking for expert advice on how to prepare for possible coronavirus cases have a whole new suite of resources to turn to.

The Centers for Disease Control and Prevention and the American College Health Association both released guidance this week on how to prepare for emergence of the new coronavirus, which causes the respiratory illness COVID-19, on college campuses. The Department of Education also issued guidance Thursday about compliance with federal financial aid requirements in the event of related disruptions and campus closures.

The CDC guidance includes information on reviewing and updating emergency operations plans; sharing informational resources with faculty, students and staff; making decisions on whether and when to suspend classes or cancel events in coordination with state and local public health officials; and ensuring continuity of safe housing and provision of meals. The CDC has also separately released guidance suggesting that colleges consider canceling study abroad and exchange programs and bring students back to the U.S.

"IHE [institutions of higher education], working together with local health departments, have an important role in slowing the spread of disease," the CDC guidance states. The guidance also notes the fact that some individuals are experiencing stigma and discrimination related to COVID-19, including people of Asian, specifically Chinese, descent -- the virus originated in China but has quickly spread to many other countries -- as well as returning travelers and emergency responders who may have been exposed.

"It is important for IHE to provide accurate and timely information about COVID-19 to students, staff, and faculty to minimize the potential for stigma on college and university campuses," the CDC guidance states. "It is also important to provide mental health support to promote resilience among those groups affected by stigma regarding COVID-19."

The guidance from the American College Health Association focuses on recommendations for preparations by student health centers as well as for the larger campus community.

The association recommends that student health centers develop a COVID-19 planning and response committee, arrange for appropriate staff training, prepare the facility for triage and isolation of possibly infected patients and develop triage and evaluation protocols, develop an internal and external alert system regarding the arrival of a potential patient, stock personal protective equipment in accordance with CDC guidelines, ensure appropriate environmental cleaning and disinfection procedures are in place, and develop a surge care plan in the event of increased demand for student health center services.

As for the broader campus community, the ACHA guidance recommends creating a campuswide working group focused on preparing for COVID-19 and developing a communications plan and plans for the possible arrivals on campus of individuals from areas affected by COVID-19 and for international travel by students, faculty or staff. The guidelines also recommend universities develop business and financial continuity plans that take into account the potential financial ramifications of the outbreak and estimated emergency funding needed to continue operating; the costs of stockpiling food, medical and other supplies; policies and procedures for rapid procurement of supplies; and continuation of payroll, among other issues.

"The ACHA COVID-19 Task Force has been hard at work fielding concerns from the college health community, posting resources and updates, and rapidly responding to new developments related to COVID-19," Jean Chin, the chair of the task force, said in a press release accompanying the new guidelines. "Our hope is that these guidelines, paired with existing campus resources and coordination with local and state health agencies, will assist schools nationwide in preparing for COVID-19 and its implications for campus communities."

The Department of Education also issued guidance on Thursday responding to concerns from colleges about how they can comply with federal financial aid policies for current students whose studies are disrupted by COVID-19. The guidance addresses financial aid implications for three groups of students -- those whose study abroad experiences have been disrupted or canceled; those who had a clinical rotation, internship or other class canceled, causing them to fall below the 12-credit-hour minimum needed to maintain enrollment as a full-time student; and those who miss classes due to illness or quarantines. It also addresses scenarios in which a college suspends face-to-face classes to prevent transmission of the virus.

“Our goal is to work with institutions and find ways to enable you to accommodate students and help them continue their education despite interruptions caused by COVID-19,” the guidance said. “The Department is providing broad approval to institutions to use online technologies to accommodate students on a temporary basis, 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 … We are also permitting accreditors to waive their distance education review requirements for institutions working to accommodate students whose enrollment is otherwise interrupted as a result of COVID-19.”

The guidance notes, however, that the department is not able to offer the flexibility to transition to online learning for foreign schools that participate in the federal financial aid program, as the Higher Education Act does not allow foreign institutions to provide distance learning to Americans participating in federal financial aid programs.

In addition to offering distance education in the event regular classes are disrupted, the guidance says that institutions "may also enter into temporary consortium agreements with other institutions so that students can complete courses at other institutions but be awarded credit by their home institution. In addition, in instances where accrediting agencies require students to complete a final number or percentage of credits in residence at the institution, accrediting agencies may waive that requirement for students impacted by COVID-19 without objection by the Department."

The guidance from the department authorizes colleges to continue paying wages to students through the federal work-study program in the event of a campus closure if certain conditions are met, and it provides flexibility on allowing students to take leaves of absence for reasons related to COVID-19 "even if the student notifies the institution in writing after the approved leave of absence has begun. In such a case, the institution may retain those Title IV funds to apply when the student continues enrollment." (Title IV is the part of the Higher Education Act that authorizes federal financial aid programs.)

It also includes instructions for returning aid funds for students who were unable to begin attending classes this term due to coronavirus-related closures (as in the case of students whose study abroad programs were canceled before the term began), and for those who withdraw for reasons related to COVID-19. The guidance also states that the Education Department does "not have the authority to waive the requirement to award or disburse Title IV funds based on a student’s actual enrollment status. For example, assuming an institution defines full-time enrollment as 12 credit hours, when a full-time student enrolled for 12 credit hours drops or withdraws from three credits, that student is now enrolled at three-quarter time status."

Jill Desjean, a policy analyst with the National Association of Student Financial Aid Administrators, which published an analysis of the Education Department guidance, praised the department's flexibility. She noted that while there are certain things the department can't do under the law, it has tried to accommodate the varied needs of higher ed institutions.

"The big concern we had were students who had gone abroad to start study abroad programs and had been pulled back," she said. "I think the department did a good job of addressing that by mentioning all the relief schools could get by offering distance ed ad hoc without having to go through department approval or accreditor approval."

Desjean said the departmental guidance is also helpful for colleges as they consider what would happen if they need to temporarily close. "The distance ed option on the table is a good one to allow schools to start making a plan," she said.

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