Expiration of the Public Health Emergency and the Impacts on Substantive Changes

How are programs affected by the end of the federal COVID-19 public health emergency as it relates to substantive changes?

In January 2023, the Biden Administration announced that the federal public health emergency, declared under Section 319 of the Public Health Service (PHS) Act, would expire on May 11, 2023. Throughout the COVID-19 pandemic, the CAA has followed guidance from the U.S. Department of Education (USDE) issued to accreditors providing flexibilities through December 31, 2020, or the last date that the national emergency is in effect, including waiving normal approval processes for institutions and programs to deliver courses through distance technologies. During the federal emergency, the CAA has temporarily waived the timelines for programs seeking approval of a permanent change for the delivery of the program via distance education. The program must seek approval in accordance with the CAA’s Substantive Change policy and procedures but has been able to forego the time to file a notice of intent form and the requirement that a change plan be submitted 12 months prior to enrollment.

What will change once the public health emergency ends?

Based on the guidance from the USDE, temporary waivers will end on the last date of the public health emergency, May 11, 2023. Once the date passes, the CAA will also end the temporary waivers related to the timelines for programs seeking approval of a permanent change for the delivery of the program via distance education. Programs must seek approval for substantive changes in accordance with the CAA’s Policy on Substantive Changes and procedures, found in the CAA Accreditation Handbook [PDF] in Chapter XI.K Expectations of Programs.

Distance education is defined as a formal education process in which 50% or more of the required graduate academic credit hours, excluding practicum, may be accrued when the learner is separated from the instructor or instructors using one or more of the technologies listed in Chapter XI.K of the CAA Accreditation Handbook, and there is support for regular and substantive interaction between the students and the instructor or instructors. The interaction may be synchronous or asynchronous.

Programs seeking approval of a proposed substantive change for a distance education modality after May 11, 2023, must adhere to the following procedures:

• agree to not enroll students in the proposed additional modality until the substantive change has been approved by the CAA.
• submit a substantive change plan at least 12 months before the enrollment of students into the proposed program. Plans must be submitted by February 1 or August 1 for consideration by the CAA.
• file a Notice of Intent at least 5 months before planned submission date (i.e., by September 1 for February 1 submission or by March 1 for August 1 submission). These notification deadlines allow sufficient time for the program to be appropriately scheduled in the on-line reporting system and then be provided access to the system to complete questions to support its request for a substantive change. If the program fails to meet the notification deadline, it will be scheduled for the next report fielding.
• provide additional information if requested by the CAA during its review, including hosting a site visit if warranted.
• provide documentation that final approval by all appropriate university and state authorities has been secured. Materials may be submitted for CAA review prior to the final approval by the authorizing body, but the CAA will not approve the plan until all approvals are final.

During the review period, programs must convey current and accurate information about the inclusion of the modality as part of the accreditation status. Once a substantive change has been submitted to the CAA for review, the program must indicate that “approval is pending” of the modality if promoting or advertising the proposed modality, as outlined in the CAA’s Public Notice of Accreditation Status policy. Programs must not suggest approval or accreditation of the proposed modality while a review is pending.

The CAA will make a final review of the substantive change materials and related correspondence and consider whether to approve the proposed changes at one of its face-to-face decision-making meetings during the year. Once approved, the program’s accreditation status will indicate the additional modality (satellite location, distance education, or contractual arrangement) that is now part of the program’s accreditation in the CAA’s listing of programs. The Accreditation Office will work with programs to make one-time adjustments for the next reporting cycle, if needed, if substantive change reviews are conducted off-cycle from the program’s normal reporting deadline.

Substantive changes related to satellite locations or contractual arrangements were not part of the temporary waivers approved due the public health emergency. These types of substantive changes will not be impacted by the end of the public health emergency and programs will follow the procedures outline above for these types of changes.

Direct any questions to accreditation@asha.org.