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Department of Education Clarifies Repeat Coursework Restrictions

September 28, 2012—The Department of Education Sept. 27 announced that graduate and professional programs are not subject to repeated coursework regulations. The regulations would prohibit students from receiving Title IV aid for any repetition of previously passed coursework required due to a student’s failure of other coursework.  In a reversal of public statements on the matter, the department confirmed that “schools may continue to follow the guidance on our website which states that the retaking coursework provision only applies to undergraduates.”

The department noted that it plans to meet with medical schools and the AAMC in the near future to discuss “the adverse impact of the retaking coursework rule for medical schools and to learn more about how medical schools’ programs are structured in terms of a student’s progression from one term to the next.”

The AAMC joined several health professions education associations in a Sept. 25 letter  to the department expressing concern over recent changes to how repeated coursework is considered in the determination of federal aid eligibility.  The letter states, “In light of the uniqueness of health professions training, the benefits of integrated curricula, and the student financial hardships imposed by the new regulations, the undersigned associations of schools of health professions request that the department exempt graduate health professions programs from the Title IV repeated coursework restrictions.” 

In the coming weeks, the department plans to publish a “Dear Colleague Letter” that will address this issue and several other questions related to the treatment of withdrawals and enrollment reporting status.  The department also suggested that it will change its policy on graduate and professional repeated coursework at a later date, presumably through the negotiated rulemaking process.


Matthew Shick, JD
Director, Gov't Relations & Regulatory Affairs
Telephone: 202-862-6116


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806