BPSS Cutting Edge News

All BPSS schools that were initially granted temporary approval under section 126.4(a) of the Commissioner’s regulations to offer theory coursework (and limited skills coursework on a case-by-case basis) through online learning modalities are now approved to offer such coursework via online learning modalities for the full duration of their approved curricula, i.e. until the date each curriculum is set to expire and requires reapproval.

In the interests of efficiency, BPSS will not re-issue approval letters for online curricula. The initial notice from BPSS reflecting temporary distance education approval, as per this guidance, shall have the force and effect of approval and shall be considered sufficient evidence of state authorization for distance education for the full duration of the approved curriculum. Such distance education approval may be rescinded for cause, based on a finding of non-compliance with the provisions of Part 126 of the Commissioner’s regulations.

At the time of curriculum reapproval, schools currently approved to offer coursework through online learning modalities will be required to submit additional information and documentation for the purpose of reapproval and meet any new requirements for online reapproval in effect at that time.

Beginning in the 2020-2021 reporting year, all schools approved to offer coursework through online learning modalities will be required to submit Occupational Education Data Survey data (due April 15, 2022) disaggregated by curricula offered in the following formats:  1) fully online; 2) hybrid/blended; and 3) face-to-face only. Schools should ensure current data collection efforts facilitate data reporting in this manner.

BPSS will consider school requests for a temporary special exemption to offer certain skills-coursework through online learning modalities under the following conditions. In addition to meeting the five criteria set forth in the March 13, 2020 Guidance Memo, School Directors must also attest and agree to meet each of the following conditions:

1. Ensure that online skills-training offered by the school affords opportunities for students to:
   • View multiple exemplar models of skills being performed, which are clearly explained, and can be broken down into steps in the right sequence.
   • Ask questions of teachers and receive feedback in real-time, while examining a few examples of skill performance in-depth.
   • Practice skills and receive immediate and quality assessment feedback from teachers.
   • Practice skills in conditions that very closely approximate the authentic real-world situations in which skills are performed.
   • Practice skills using instructional equipment that is comparable to the equipment currently used by business or industry in the occupational area for which the curriculum was developed, at no additional cost to the student.
2. Limit online skills courses to no more than 10 students per course session, taught by at least one appropriately licensed teacher. 
   *New Clarification – a course session may have 20 students if there are 2 appropriately licensed instructors (maintaining a 1:10 teacher to student ratio).
3. Adhere to and clearly disclose the following information to students, in writing, prior to their actively agreeing in writing to proceed with online skills training (email disclosure and agreement will count):
   • Students may exercise any of the three following options:  1) proceed with online skills-training; 2) take a leave of absence without penalty or additional cost; 3) withdraw from the program with a refund per their enrollment agreement. And, make clear to students that should they initially choose option 1), they may also exercise option 2) and 3) at any point in the training thereafter.
   • Identify the specific skills coursework and corresponding clock hours that can be completed online.
   • Identify the specific skills coursework and corresponding clock hours that cannot be completed online because there is no comparable at-home alternative to the equipment currently used by business or industry, or because performance of the skill outside the direct supervision of an expert would be a safety risk, if any. And, disclose that such coursework and corresponding clock hours must be completed on-site once the school location can legally and safely re-open.
   • For every hour of skills instruction delivered online, upon the request of the student or program completer, the school will provide one-hour of on-site guided skills-practice without undue delay (hours grouped together for full performance of a skill) once the school can legally and safely re-open, at no additional cost. (If a student or program completer wants to practice skills learned initially online, on-site with guidance after a re-opening, the school will provide that opportunity).
4. Ensure that the online skills training will enable students to develop those skills and competencies required for employment in the occupational area for which the curriculum was approved.

Certain skills curriculum and courses are not eligible for special exemption for online approval. Curricula and coursework not currently eligible for online delivery include, but are not limited to: Nurse Aide/Assistant, Dental Assistant, Dialysis Technician, EKG, Home Health Aide/Personal Care Aide, Medical Assistant – Clinical, Patient Care Technician, Phlebotomy, Ultrasound, Automotive Repairs, Cosmetic Laser Hair Removal, Microblading/Permanent Make-up.

Procedure for Making a Request

To request a special exemption, School Owners/Directors should send an e-mail to their Field Associate, and copy Charmaine Grant, Supervisor of Education Programs. In the e-mail, School Owners/Directors must explicitly attest and agree to meeting each of the four conditions identified above. In addition, where appropriate, School Owners/Directors should provide a very brief, but cogent explanation of how each provision is being met.

Notes

• Any temporary special exemptions granted to offer skill-coursework online will sunset when the schools licensed location can legally and safely re-open. However, it is important to note that schools’ temporary special exemption to offer theory coursework online will remain in effect for an extended period of time after a school’s licensed location has reopened in order to facilitate transitions and safe re-entry scheduling on-site.
• Schools granted a temporary special exemption must consult with state and federal student financial aid oversight bodies, including but not limited to ACCES-VR, accrediting agencies, and United States Departments of Education and/or Veterans Affairs, to determine whether any additional approvals or restrictions apply.

Any questions may be directed to your BPSS Field Associate. Field Associate e-mail contact information is available here at the BPSS staff webpage.