Waivers Related to MSCHE Policies and Procedures and Other COVID-19-Related Actions
The Middle States Commission on Higher Education (Commission) has modified certain policies and procedures to assist institutions with adjusting to COVID-19 interruptions. These modifications are aligned and consistent with guidance provided by the United States Department of Education (USDE) grant of temporary flexibilities to institutions of higher education and to accreditors and approved by the Executive Committee or Commission as noted. The Commission alerted institutions to these modifications through email, recorded broadcasts, and surveys. A timeline of these waivers is provided below.
March 4, 2020, Delay Spring 2020 international visits and restrict all international travel
On March 4, 2020, the Executive Committee acted to delay the on-site evaluation visit to international institutions for Spring 2020. The Executive Committee acted further to restrict all international travel until further notice.
March 6, 2020, Temporary Waivers related to Substantive Change Policy and Procedures
On March 6, 2020, the Executive Committee acted to waive the MSCHE distance education review requirements in the Substantive Change Policy and Procedures for institutions working to accommodate students whose enrollment is otherwise interrupted as a result of COVID-19.
The Executive Committee acted further to waive the MSCHE contractual agreements review requirements in the Substantive Change Policy and Procedures for institutions working to accommodate students impacted by COVID-19 so that students can complete courses at other institutions but be awarded credit by their home institutions.
March 11, 2020, Temporary Waiver related to Accreditation Review Cycle and Monitoring Policy and Procedures
On March 11, 2020, the Executive Committee acted to temporarily waive on-site visits required in the Commission’s Accreditation Review Cycle and Monitoring Policy and Procedures in support of virtual visits in response to the coronavirus (COVID-19) and in accordance with anticipated USDE guidance. Virtual visits will not be allowed for those institutions under circumstances that require on-site review such as applicant institutions, institutions on probation, and institutions with concerns that warrant on-site review.
April 16, 2020, Actions on March 6, 2020 Waivers
On April 16, 2020, the Executive Committee acted on the waivers approved on March 6, 2020 as follows:
Domestic Institutions:
To support institutions and to align with the United States Department of Education (USDE) guidance, the Executive Committee acted to temporarily waive the substantive change requirements for distance education for institutions not approved to offer this alternative delivery method.
International Institutions:
In response to additional USDE guidance published April 3, 2020, the Executive Committee acted to extend the temporary distance education waivers for international institutions and align the waivers with any clarifications relating to the USDE guidance.
April 16, 2020, Temporary waiver related to Substantive Change Policy and Procedures requirements for distance education
Substantive Change Policy and Procedures:
In accordance with the USDE Office of Postsecondary Education Updated Guidance published April 3, 2020, which encouraged accrediting agencies to develop new policies and procedures to support the rapid approval of distance education programs for institutions working to accommodate students whose enrollment is otherwise interrupted as a result of COVID-19, the Executive Committee acted to grant MSCHE staff the authority to expedite the MSCHE substantive change process, as allowed under the USDE April 3, 2020 Guidance, by temporarily modifying the Substantive Change Policy and Procedures and Substantive Change Guidelines for those institutions seeking to include the distance education alternative delivery method within the institution’s scope of accreditation.
The USDE subsequently extended its temporary flexibilities and allowed those institutions given temporary approval to offer programs through an alternative delivery method to continue their delivery through alternative methods through December 31, 2020. Institutions that wish to continue offering programs through the alternative delivery methods are therefore required to follow the Commission’s established Substantive Change Policy and Procedures and Substantive Change Guidelines.
April 16, 2020, Actions to delay certain visits required in Accreditation Review Cycle and Monitoring Policy and Procedures
Grant of Delay for Visit (Accreditation Review Cycle and Monitoring Policy and Procedures):
As circumstances relating to the coronavirus (COVID-19) continued to change rapidly for institutions, systems, and states, the Commission determined that applicant institutions, institutions on probation, and institutions with concerns that warrant on-site review would conduct delayed visits. The Commission also offered options to institutions and teams to delay on-site Spring 2020 visits.
For institutions scheduled to host an on-site evaluation visit, the Executive Committee acted as follows: To delay the On-Site Evaluation visit scheduled for Spring 2020 due to extraordinary circumstances related to coronavirus (COVID-19) interruptions and to continue accreditation. To note the institution remains accredited during a delay granted by the Commission. The Evaluation visit will be scheduled in accordance with Commission policy and procedures.
For institutions scheduled to host a follow-up visit, the Executive Committee acted as follows: To delay the On-Site Follow-Up visit scheduled for Spring 2020 due to extraordinary circumstances related to coronavirus (COVID-19) interruptions and to continue accreditation. To note the institution remains accrediting during a delay granted by the Commission. The Follow-Up visit will be scheduled in accordance with Commission policy and procedures.
The Commission also postponed substantive change follow-up visits until travel is permissible.
April 16, 2020, Principles related to flexibilities in response to COVID-19
The Executive Committee endorsed the following principles related to the flexibilities in response to COVID-19:
- The Commission will offer flexibility in the timeline for team chairs to conduct on-site preliminary visits for institutions in the 2020-2021 cohort. (Accreditation Review Cycle and Monitoring Procedures)
- The USDE guidance affords the Commission discretion on the timing of actions based on their requirement of a virtual site visit and follow-up, in person or verification visit. The Commission will take action following all virtual site visits but prior to the verification visit required in the USDE guidance, except in the non-compliance circumstances described below:
- For institutions receiving non-compliance as a result of a virtual visit, the Commission will act to postpone the decision, request a supplemental information report (SIR) and conduct a follow-up, in-person visit. This visit will serve the dual purpose of a MSCHE follow-up visit, and the verification visit required by USDE guidance.
- During a virtual site visit, if an institution was found in compliance by a team, but out of compliance by the Committee, the Commission will waive the Advance Notice of Non-Compliance Recommendations Procedures temporarily in lieu of an action of postponement with a request for an SIR and follow-up visit.
- The purpose of the follow-up, in person visit will be similar to a substantive change follow-up visit, which is shorter in duration and used only to verify evidence and information provided to the team.
- In the event that future guidance issued by the USDE no longer requires the verification visit, the Commission should not require such unless the recommendation of non-compliance resulted from the team evaluation or at the Committee-level. Team chairs and MSCHE vice president staff liaisons have visited institutions as part of the Commission’s on-site evaluation procedures, and the additional burden of a verification visit is unnecessary.
May 21, 2020, Waiver related to Accreditation Review Cycle and Monitoring Policy and Procedures
On May 21, 2020, the Executive Committee acted to waive on-site visits required in the Commission’s Accreditation Review Cycle and Monitoring Policy and Procedures for institutions undergoing self-study evaluation visits in Fall 2020 in support of virtual visits in response to the coronavirus (COVID-19). Virtual visits will not be allowed for those institutions under circumstances that require on-site review such as applicant institutions, candidate institutions, institutions on probation, and institutions with concerns that warrant on-site review.
June 24, 2020, Actions related to Accreditation Review Cycle and Monitoring Policy and Procedures
On May 15, 2020, the United States Department of Education (USDE) provided additional guidance related to the use of virtual visits. Clarification was provided regarding the in-person, follow-up visit that was required after a virtual visit. The USDE guidance requires a focused site-visit to confirm the presence of facilities to meet the Department’s requirements for an on-site visit following the full virtual site visit. The USDE guidance pertains to on-site evaluation visits as opposed to follow-up visits. On June 24, 2020, the Executive Committee acted as follows:
- Verification Visits following Virtual Follow-Up Visits will not be required.
- Verification Visits to Branch Campuses and Additional Locations will not be required for those where branch campuses/additional locations that hosted virtual evaluation visits were either able to host onsite visits to locations prior to the travel ban, or have conducted substantive change follow-up visits within the last accreditation cycle.
The Middle States Commission on Higher Education (MSCHE) is pleased to provide a recorded broadcast for its membership and the public highlighting recent Commission activities and planning.
MSCHE has provided a recorded webinar to assist institutions and evaluators conducting virtual site visits. The Virtual Site Visit Training Module addresses the temporary flexibility provided by the United States Department of Education to address coronavirus (COVID-19) impacted institutions and accrediting agencies. Please note that this recorded webinar is a supplement to training already provided to Team Chairs and peer evaluators and does not negate any previous training.
On behalf of the Middle States Commission on Higher Education (MSCHE) and the President’s office, MSCHE senior leadership is providing a recorded webinar to share important messaging and deliver information to all MSCHE constituents, that is accurate as of the date and time of this webinar.