CAAHEP Communiqué December 2023

CAAHEP Communiqué

December 2023

From the President

Donald A. Balasa, JD, MBA

2023-2024 CAAHEP President

USDE Issues Final Regulations for Title IV of the HEA (Part 1)

The United States Department of Education (USDE) promulgated a set of final regulations for Title IV of the Higher Education Act (HEA) in the October 31, 2023, Federal Register. These regulations address financial responsibility, administrative capability, certification procedures, and ability to benefit, and reflect changes to the wording of the proposed regulations in the USDE May 19, 2023, Notice of Proposed Rulemaking (NPRM). These final regulations will go into effect July 1, 2024.

The October 31, 2023, Federal Register includes comments from the public about its May 19, 2023, NPRM as well as the USDE responses to these comments. The final regulations reflect changes prompted by the comments. The following will point out changes in wording of the regulations that are of relevance to the allied health community.

Gainful Employment (GE) Programs Must Meet Licensure or Certification Requirements

One of the most controversial elements of the USDE May 19, 2023, NPRM was the requirement that graduates of gainful employment (GE) programs be eligible for licensure or certification requirements in the profession/occupation. GE programs not meeting this requirement would not be allowed to receive Title IV funding. The following public comment was published in the October 31, 2023, Federal Register:

Comment: Several commenters observed that the proposed regulations for institutions to satisfy the educational prerequisites for State licensure or certification requirements would impose an infeasible burden for both schools and State licensing boards. Many commenters reported that in previous determinations of licensure compliance, such investigations were time-consuming and costly and often yielded no definitive answer. According to these commenters, inquiries to State bodies frequently resulted in no reply. The commenters further explained that State rules vary widely and are subject to frequent changes…The commenters asked how the Department [of Education] could impose this requirement given that we cannot guarantee the necessary State cooperation.

In the response to the above comment, the Department of Education made it clear that it was not going to compromise on this fundamental element of the gainful employment regulations. Here is the USDE response:

Discussion: When a student enters a program that prepares them for an occupation that requires licensure or certification, they should have the expectation that finishing that program will allow them to fulfill the educational requirements necessary for getting the necessary approval to work in that field. We are concerned that students attending programs that do not have those necessary approvals will not only fail to achieve their educational goals but may also end up with earnings far below what they expected. Such programs also represent a waste of taxpayer money, as the Federal Government is supporting credits that cannot be redeemed for their stated purpose. The Department [of Education] agrees that complying with this requirement will create costs for institutions, but we also believe those costs are worthwhile to protect student and taxpayer investments. Institutions are not required to participate in the title IV programs, both overall and on a programmatic basis. If they do not want to take the necessary steps to protect against wasted investments, then they can choose to make these programs not eligible for Federal aid.

After weighing all the comments the USDE decided on the following wording for this section of the final rule:

§ 668.14 Program participation agreement.

…

(32)…

[for] each student who enrolls in a program on or after July 1, 2024, and attests that they intend to seek employment, the institution must determine that each program eligible for title IV, HEA program funds—(i) Is programmatically accredited if the State or a Federal agency requires such accreditation, including as a condition for employment in the occupation for which the program prepares the student, or is programmatically pre-accredited when programmatic pre-accreditation is sufficient according to the State or Federal agency; [and] (ii) Satisfies the applicable educational requirements for professional licensure or certification requirements in the State so that a student who enrolls in the program, and seeks employment in that State after completing the program, qualifies to take any licensure or certification exam that is needed for the student to practice or find employment in an occupation that the program prepares students to enter;

Another debated provision of the USDE NPRM of May 19, 2023, was the state laws with which schools and their gainful employment programs had to comply. The USDE included the following comment in the October 31, 2023, Federal Register:

Comment: Many commenters noted that it is not reasonable to presume that students will necessarily pursue their career in the State in which they initially enroll in their program. For example, several commenters offered that the students might be members of the military or family thereof and only be temporarily located in that State, or they might live near a State border and intend to find employment in a neighboring State or move to a State where jobs are more available.

The Department of Education saw merit in the above mention comment:

Discussion: [W]e do agree that there are instances in which a student, such as a military-connected student, might plan to leave the State they reside in and intend to seek employment in another State. Therefore, we have added language to § 668.14(b)(32) to say that an institution can consider the State a student is in at their time of initial enrollment, or the State identified in an attestation from a student where they intend to seek employment in another State. We would note that the student must identify a specific State and the institution’s program must meet the requirements of that State.

The USDE settled on the following language for the final rule to take into account the reality that graduates may want to (or have to) work in their occupation/profession in a state other than the state of the gainful employment program. The new language is italicized:

§ 668.14 Program participation agreement.

…

(32)…

In each State in which: (a) the institution is located; [and] (b) students enrolled by the institution in distance education or correspondence courses are located, as determined at the time of initial enrollment…[for] each student who enrolls in a program on or after July 1, 2024, and attests that they intend to seek employment, the institution must determine that each program eligible for title IV, HEA program funds—…

[See the above language in 668.14(32) of the final regulations.]

Read USDE Issues Final Regulations for Title IV of the HEA Part 2...

In Memoriam

It is with heavy hearts that CAAHEP informs you of the passing of Jennifer (Jenny) Spegal, CMA (AAMA), MT, MEd, a devoted volunteer of CAAHEP, who served at all levels of the organization, and currently held the position of CAAHEP Board Secretary. Jenny began her service in CAAHEP as a member of the Medical Assistant Education Review Board (MAERB), where she was a site visitor and CoA Chair. She was appointed to the Commission representing MAERB and was elected to the CAAHEP Board in 2018, where she served two terms. Jenny served as Vice President of the Board in 2020-2022. She served on many CAAHEP Committees and presented at numerous CAAHEP events. Jenny had a 30-year career at Sinclair Community College, where she served as Assistant Dean for the last five years. She was so generous with her time, expertise, and friendship; we will miss her.

CAAHEP Issues Position Statement Regarding SCOTUS Decision on Race in Admissions

On November 17, 2023, the Commission on Accreditation of Allied Health Education published a position statement on the U.S. Supreme Court ruling in Students for Fair Admissions, Inc. v. President and Fellows of Harvard College and Students for Fair Admissions, Inc. v. University of North Carolina et al in June 2023, finding that the use of race in admissions policies applied by the University of North Carolina and Harvard College violate the Equal Protection Clause of the Fourteenth Amendment and Title VI of the Civil Rights Act of 1964.

As a programmatic accreditor whose mission is to provide value to stakeholders by setting standards for quality assurance in health professions education, the Commission on Accreditation of Allied Health Education Programs (CAAHEP) reaffirms its commitment to giving all people equal access to education and entry into practice in the health professions. CAAHEP respects institutional autonomy as it relates to admission practices (CAAHEP Policies & Procedure; Policy 107), and as stated in CAAHEP Standard V.B., “All activities associated with the program…, including student admission… must be non-discriminatory and in accord with federal and state statutes, rules, and regulations.”

The full statement is posted on the CAAHEP website.

CAAHEP Bylaws

The Commissioners at the Special Meeting of the Commission on Accreditation of Allied Health Education Programs on October 26, 2023, approved the proposed changes to the CAAHEP Bylaws. The new version is posted on the CAAHEP website.

Nominations for New Higher Education Program Integrity and Institutional Quality Rulemaking Panel Sought

The U.S. Department of Education (Department) announced that it will publish a notice in the Federal Register establishing a negotiated rulemaking committee that will meet to rewrite regulations that address some of the “nuts and bolts” of Title IV program integrity and institutional quality under the Higher Education Act. In the notice, the Department requests nominations for non-Federal negotiators and sets dates for negotiation sessions.

“The Department is committed to expanding access to opportunity through quality higher education and supporting students to achieve their college dreams,” said U.S. Secretary of Education Miguel Cardona. “Our regulatory efforts reflect our laser-focus on ensuring that students are well served by the higher education institutions they attend and that our federal student aid programs are helping them to attain postsecondary success."

Read the full U.S. Department of Education's press release here. To submit nominations for committee or subcommittee spots, please email [email protected]. Nominations must be received by December 13, 2023. Please find the official copy of the Federal Register Notice here for additional details on requirements for nominees.

CAAHEP Symposium 2024

There's an amazing line-up of speakers and presentations for the 2024 CAAHEP Symposium! The Symposium is being held at the beautiful One Ocean Resort & Spa in Atlantic Beach, Florida. Don't miss the opportunity to learn more about higher education accreditation, what's going on in the allied health professions workforce, updates on NC-SARA, how to advocate for health professions education, and so much more, all while networking with your peers! Check out each presentation from the speakers below by clicking on their image. Register today to reserve your seat (in-person or virtually), review the agenda here, and learn more about the entire CAAHEP Symposium on the CAAHEP website.

2024 Symposium Sponsors

Thank you to the following companies who have recently signed on as sponsors of the 2024 CAAHEP Symposium! Sponsorships are still available. Please see the Sponsorship/Exhibitor Prospectus for all the details.

Platinum Educational Group is a global leader in online testing, tracking, scheduling, and reporting. Our areas of focus include the Emergency Medical Services, Allied Health, and Nursing industries.

Exxat is an all-in-one Allied Health management tool that streamlines managing data, contracts, placements, compliance, case logs, evaluations, curriculum mapping, and so much more!

Survey Shows Enthusiasm for AEMT Voluntary Accreditation

Reprinted from the CoAEMSP e-Newsletter

The Committee on Accreditation of Educational Programs for the Emergency Medical Services Professions (CoAEMSP) recently surveyed 293 AEMT Program Directors regarding their potential interest in voluntary accreditation.

The key finding: AEMT Program Directors are enthusiastic about voluntary AEMT accreditation.

Two-thirds of respondents (65%) believe voluntary accreditation for AEMT programs would potentially benefit their program and 59% of respondents are likely to seek voluntary accreditation.

Half of the respondents (50%) are from CAAHEP accredited Paramedic programs (132), and 65% of them are very or somewhat likely to pursue AEMT accreditation.

The survey also revealed that AEMT Program Directors are familiar with programmatic accreditation.

More than three-quarters of respondents (78%) are familiar with accreditation, and 4 out of 5 respondents (83%) are familiar with CAAHEP or CoAEMSP.

Visit the CoAEMSP website for the full survey results and more information on AEMT voluntary accreditation. Register to attend a Town Hall meeting on Friday, December 15, 2023, @ 1:00 PM Central Time. This will be an opportunity to discuss the policies for AEMT education programs that will be released on December 4, 2023.

CAAHEP Office Closure Notice

The CAAHEP offices will be closed December 22, 2023, through January 1, 2024, for the holidays.

CAAHEP Accreditation Actions

Each profession in the Commission on Accreditation of Allied Health Education Programs (CAAHEP) system has a Committee on Accreditation (CoA) that consists of experts in the profession who are responsible for reviewing programs and making appropriate recommendations for accreditation to CAAHEP. CAAHEP reviews recommendations received from its CoAs in each profession, assures due process was followed and takes final action on an accreditation status.

CAAHEP took the following actions at its November 17, 2023 meeting. Actions are identified by profession, action taken, date of the next comprehensive evaluation, and whether a progress report to improve program compliance is required. In some cases, the concentration and/or degree are also specified. Where available, a link to each program's website is provided below. To view a copy of the most recent accreditation award letter for a program, which includes information about the accreditation decision, visit the program’s listing on the Find an Accredited Program section of the CAAHEP Website.

The following programs were found to be in compliance with the accreditation Standards and Guidelines and were granted continuing accreditation, with the next comprehensive evaluation to occur no later than 2028. These actions require no progress report and were approved on the consent agenda.

Cardiovascular Technology

Medical University Hospital Authority, Columbia, SC (Adult Echocardiography, Certificate)

Medical University Hospital Authority, Columbia, SC (Noninvasive Vascular Study, Certificate)

Diagnostic Medical Sonography

Rowan College of South Jersey, Sewell, NJ (Abdominal-Extended)

Rowan College of South Jersey, Sewell, NJ (Obstetrics and Gynecology)

The following programs were found to be in compliance with the accreditation Standards and Guidelines and were granted continuing accreditation, with the next comprehensive evaluation to occur no later than 2030. These actions require no progress report and were approved on the consent agenda.

Cardiovascular Technology

Northside Hospital, Atlanta, GA (Adult Echocardiography, Certificate)

Cytotechnology

Indiana University - Purdue University Indianapolis, Indianapolis, IN

Ronald Reagan UCLA Medical Center, Los Angeles, CA

The following programs were found to be in compliance with the accreditation Standards and Guidelines and were granted continuing accreditation, with the next comprehensive evaluation to occur no later than 2033. These actions require no progress report and were approved on the consent agenda.

Diagnostic Medical Sonography

Aurora Health Care Metro Inc. St. Luke's Medical Center, Milwaukee, WI (Abdominal-Extended)

Aurora Health Care Metro Inc. St. Luke's Medical Center, Milwaukee, WI (Obstetrics and Gynecology)

Aurora Health Care Metro Inc. St. Luke's Medical Center, Milwaukee, WI (Adult Cardiac)

Aurora Health Care Metro Inc. St. Luke's Medical Center, Milwaukee, WI (Vascular)

Harper College, Palatine, IL (Abdominal-Extended)

Harper College, Palatine, IL (Obstetrics and Gynecology)

Harper College, Palatine, IL (Adult Cardiac)

Surgical Technology

Delta College, University Center, MI (Associate)

Elgin Community College, Elgin, IL (Associate)

Lackawanna College, Scranton, PA (Associate)

Moberly Area Community College, Columbia, MO (Associate)

The following program was found to be in substantial compliance with the accreditation Standards and Guidelines, with one or more Standards requiring a progress report to be submitted to the appropriate Committee on Accreditation (CoA). The program was granted continuing accreditation, with the next comprehensive evaluation to occur no later than 2028.

Neurodiagnostic Technology

American Institute of Medical Science and Education, Piscataway, NJ

The following programs were found to be in compliance with the accreditation Standards and Guidelines and were granted initial accreditation, with the next comprehensive evaluation to occur no later than 2028. These actions require no progress report and were approved on the consent agenda.

Anesthesiologist Assistant

Nova Southeastern University-Denver, Centennial, CO

University of New Mexico, Albuquerque, NM

Diagnostic Medical Sonography

Bucks County Community College, Bristol, PA (Abdominal-Extended)

Bucks County Community College, Bristol, PA (Obstetrics and Gynecology)

Gurnick Academy of Medical Arts-Sacramento, Sacramento, CA (Abdominal-Extended)

Gurnick Academy of Medical Arts-Sacramento, Sacramento, CA (Obstetrics and Gynecology)

Sovah School of Health Professions, Danville, VA (Adult Cardiac)

Exercise Sciences

Texas A&M University-Kingsville, Kingsville, Texas

Surgical Technology

St. Petersburg College, Pinellas Park, FL

The following program was found to be in substantial compliance with the accreditation Standards and Guidelines, with one or more Standards requiring a progress report to be submitted to the appropriate Committee on Accreditation (CoA). The program was granted initial accreditation with the next comprehensive evaluation to occur no later than 2028.

Recreational Therapy

The University of Southern Mississippi, Hattiesburg, MS

The following program had a transfer of sponsorship approved with a status of continuing accreditation, with the next comprehensive evaluation to occur no later than 2029. This action requires no progress report and was approved on the consent agenda.

Polysomnographic Technology

The University of North Carolina at Chapel Hill, Chapel Hill, NC (Baccalaureate)

The following program had a transfer of sponsorship approved with a status of continuing accreditation, with the next comprehensive evaluation to occur no later than 2033. This action requires no progress report and was approved on the consent agenda.

Surgical Technology

East Central College, Rolla, MO (Associate)

The following programs were placed on probationary accreditation, with one or more Standards requiring critical attention and timely resolution to bring the program into compliance with the Standards and Guidelines, and a progress report required to be submitted to the appropriate Committee on Accreditation (CoA).

Surgical Technology

Jefferson Community and Technical College, Louisville, KY (Associate)

Keiser University-Clearwater, Clearwater, FL (Associate)

Acknowledgments

The following statuses do not require action by the CAAHEP Board of Directors and were acknowledged by the Board at its November 17, 2023 meeting.

The program sponsors requested voluntary withdrawal of CAAHEP accreditation for the following programs:

Medical Assisting

Metro Technology Center, Oklahoma City, OK

Northwestern Health Sciences, Bloomington, MN

Surgical Technology

Altierus Career College-Norcross, Norcross, GA

The following programs held inactive status; students may not be enrolled in the program during a period of inactive status: