Department of Education Provides Clarifying Guidance on Clinical Rotation Requirements 

On October 24, the Department of Education released a set of final regulations seeking to strengthen oversight of institutions of higher education which participate in federal student aid programs. These regulations, which are set to go into effect on July 1, 2024, impact PA education by reinforcing existing accreditation standards pertaining to programs’ responsibility for securing clinical rotations for students. 

In the Department’s proposed administrative capability rule released in May, the administration sought to impose new federal standards for clinical rotation facilitation, proposing that institutions must “[provide] students, within 45 days of successful completion of other required coursework, geographically accessible clinical or externship opportunities related to and required form completion of the credential or licensure in a recognized occupation.”

In comments submitted to the Department in response to this requirement, PAEA highlighted several areas of concern with the proposal including the ambiguous definition of “geographically accessible,” the potential of this requirement to disrupt rural training tracks facilitated by programs, and the unintended consequences for student debt associated with increased clinical site payments.  

In the Department’s final rule, administration officials responded to these and similar concerns raised by other stakeholders by providing significant new flexibility, particularly for programs intended to lead to professional licensure. While the Department declined to offer a formal definition of “geographically accessible,” the administration protected both rural training tracks and the ability of programs to facilitate remote rotations for students, stating, “A clinical experience tied to a highly specialized field as part of a graduate program may see a geographically accessible option as one that is in another part of the country.” 

In addition to providing concessions pertaining to remote clinical rotations, the Department also responded to stakeholder concerns regarding the inflexibility of the 45-day requirement in the guidance accompanying the final rule. Specifically, the administration clarified, “The requirement is that institutions provide the students with the opportunity within 45 days of successful completion of other required coursework. That does not mean the experiences must start exactly within 45 days. However, the Department will consider whether a pattern where these experiences start well outside reasonable periods, e.g., offering a spot that starts in a year so the student has an extended gap after finishing their coursework is in fact a sign that an institution is not abiding by this requirement and does not have sufficient spots for clinical or externships and thus should result in a finding of a lack of administrative capability.”  

PAEA’s Government Relations team is committed to continuing its advocacy on behalf of programs through the federal regulatory process and assisting programs in ensuring high-quality clinical education for students. This team will also keep members informed about opportunities to support clinical rotations via federal and state policy. Members with questions about the Department’s final rules are invited to contact Tyler Smith at