FAQ’s and Statement Regarding Meeting Clinical Requirements

UPDATED 8/20/20 (see new items #8)

The COA recognizes the serious impact that COVID-19 is having on programs and Student Registered Nurse Anesthetists (SRNAs). The COA continues to monitor measures being taken to control the spread of COVID-19 and their potential current and future impact on nurse anesthesia programs. This includes guidance from regulatory agencies such as the U.S. Department of Education (USDE) and Council on Higher Education Accreditation (CHEA). As measures to control the spread of COVID-19 continue to evolve, programs (as well as the COA’s community of interest) will be notified if there are changes to accreditation requirements as a result of these measures. Please refer to the following COA Statement Regarding Alternative Method to Meet Clinical Experiences Requirements for Programs with Spring, Summer and Fall 2020 Completion Dates for additional details.

The COA supports actions being taken to ensure the health, safety and security of SRNAs, faculty, patients, and other stakeholders. The COA recognizes that programs may need to implement strategies different from normal operating procedures during this unprecedented period. These strategies may be influenced by individual programmatic and institutional policies and procedures; local, state and federal regulations; and possible variations in the spread of COVID-19. Guidance provided by USDE allows accrediting agencies some flexibility in addressing these circumstances. The COA is providing the Frequently Asked Questions (FAQs) below to assist programs in remaining compliant with the COA’s Standards, Policies, and Procedures during this emergency.

While an office closure has been implemented for all COA and AANA staff, actions have been taken to ensure the accreditation specialists and the accreditation office are accessible ([email protected] or 847-655-1160). Inquiries related to COVID-19 can be submitted using the Contact Us section of the COA website, or by contacting the accreditation office directly.

1. How Has COVID-19 Impacted Scheduled Onsite Reviews and Accreditation Decisions? (New – 4/13/20)

The COA maintains a list of all programs scheduled for onsite reviews and accreditation decisions at its upcoming meetings. To ensure the safety of program administrators, faculty, students, COA onsite reviewers, and other individuals involved in the onsite review process, the COA has determined that it will postpone all onsite visits previously scheduled for Spring 2020 (with accreditation decisions for impacted programs previously scheduled for the October 2020 COA meeting). COA staff will continue to communicate with the impacted programs regarding the rescheduling of these reviews and decisions. In the meantime, please note that the COA will extend the period of accreditation of any programs that have experienced a change in scheduled visit and decision dates as a result of the COVID-19 crisis.

2. What procedures must be followed for programs to implement distance education (DE)?

The COA is providing broad approval to programs to use DE to accommodate Student Registered Nurse Anesthetists (SRNAs) on a temporary basis, without going through the COA approval process. Programs may proceed in implementing new DE offerings or expanding their current DE offerings to 50% or more of the curriculum as a result of
COVID-19 restrictions to meet the needs of the program and SRNAs. Approval of DE applications for this purpose is not required, however, programs are required to notify their accreditation specialist via email If the DE changes are going to be used past the time when COVID-19 restrictions are in place the program must submit a DE application and fee to the COA for approval when campus operations return to normal. The requirement for submission of a DE application and fee is only being waived for the time when COVID-19 restrictions are in place and face-to-face teaching is prohibited.

3. What procedures must be followed for programs to complete annual clinical site visits?

Per the COA’s “Clinical Sites – Maintenance” policy (ref. Accreditation Policies and Procedures, C-14), programs are required to conduct clinical site visits in person a minimum of once per year; however, the COA recognizes that travel and other restrictions currently in place may inhibit programs’ ability to complete clinical site visits in accordance with this requirement. Programs will not be considered out of compliance with COA policy if they are unable to meet this requirement as a result of COVID-19 restrictions, though the COA asks that programs document in their program records any postponements of annual site visits due to COVID-19 and resume clinical site visits as soon as practicable following the lifting of these restrictions.

4. Can SRNAs continue clinical rotations?

The COA is aware that the majority of programs have experienced SRNAs being removed from clinical sites. Decisions regarding the continuation of clinical rotations fall under the purview of programs, their conducting institutions, and clinical sites. Programs must follow their institution and program policies and procedures in addressing changes in SRNAs’ access to clinical experiences due to this national pandemic.

5. What factors should be considered in determining whether SRNAs should be assigned to clinical?
(Revised 4/13/20)

Programs and their conducting institutions should make the decision based on their policies and procedures. The actions taken by the program must support the health and safety of the SRNAs, faculty, patients, and other stakeholders. Programs must ensure that students assigned to clinical have personal protective equipment (PPE) available. Programs are encouraged to visit the AANA website page on Practice Resources – Coronavirus Disease (COVID-19) for detailed information regarding PPE. It also is recommended that programs review the AANA, ASA, APSF and AAAA Joint Statement on Use of Personal Protective Equipment During COVID-19 Pandemic.

6. Must the clinical supervision requirements detailed in the Standards be followed for SRNAs who are able to continue clinical rotations during this pandemic?

Yes. No changes have been made to the accreditation requirements regarding clinical supervision. Please refer to Standard V, Criteria E10, E11, and E13 in the 2004 Standards for Accreditation of Nurse Anesthesia Educational Programs, Standard F.5, F.7, and F.8 in the Standards for Accreditation of Nurse Anesthesia Programs – Practice Doctorate, and the Glossary definition of “Clinical supervision” in both manuals for additional details.

7. If senior SRNAs cannot continue clinical rotations but have met the COA’s minimum required clinical hours and experiences, can they graduate on schedule? (Revised 4/13/20)

Programs are required to ensure that graduates demonstrate the ability to meet all of the required Graduate Standards and have met the required minimum clinical hours and experiences as defined in the Standards. If a program’s required number of clinical hours and experiences is greater than the COA’s minimum requirement the program has the discretion to decrease or alter its requirements. However, a program’s required number of clinical hours and experiences cannot be less than the COA’s minimum requirements.

The decision on whether or not SRNAs continue in their clinical education beyond their scheduled graduation date should be made by the program and conducting institution based on their policies and procedures. The actions taken by the program must support the health and safety of the SRNAs, faculty, patients, and other stakeholders.

SRNAs must complete the program’s stated length. Programs are required to have continuous didactic curriculum in the event that clinical is suspended. Curricular modifications intended to keep SRNAs actively engaged in learning during the suspension of clinical rotations and designed to fulfill the length of the program may be made. These modifications must be based upon and consistent with program and institutional policies. Examples of learning activities include (but are not limited to) virtual simulation, journal clubs, case presentations, scholarly work, and review in preparation for the National Certification Examination.

A program may be able to move its completion date earlier than originally scheduled while still meeting the accreditation requirement that SRNAs complete the program’s stated length. Programs must contact their accreditation specialist if the program is seeking an earlier completion date to determine if this meets accreditation requirements, prior to making a change.

8. What are the COA’s expectations if senior SRNAs cannot continue clinical rotations and have not met the COA’s minimum required clinical hours and experiences? (Revised 8/20/20)

In response to COVID-19’s impact on nurse anesthesia programs, the COA has investigated programs with Spring (i.e., April, May, and June), Summer (i.e. July, August and September), and Fall (i.e. October, November, and December) 2020 completion dates and potential alternative methods for meeting clinical experiences requirements for SRNAs not meeting the requirements. After careful consideration the COA approved an Alternative Method for the use of simulated experiences to meet certain case types. Please refer to the following COA Statement Regarding Alternative Method to Meet Clinical Experiences Requirements for Programs with Spring, Summer and Fall 2020 Completion Dates for additional details.

9. Many clinical facilities have an urgent need for additional staff at this time. Can SRNAs work as critical care RNs in clinical sites?

The AANA has issued a position statement for CRNAs assuming critical care responsibilities during the COVID-19 pandemic. This statement is for CRNAs only – NOT SRNAs.

Clinical hours completed as part of the nurse anesthesia program should be directly related to nurse anesthesia education. SRNAs may work as critical care RNs on their own time provided this is not prohibited by the program’s policies. If an SRNA chooses to work as an RN during this time, the SRNA must work solely as an RN, and it must be clear the SRNA is not employed as a CRNA or SRNA by title or function. Further, the time and activities working as an RN do not count as clinical anesthesia hours and/or clinical experiences required for the nurse anesthesia educational programs.

10. Are there wellness resources available to help CRNAs and SRNAs cope with the stress of the pandemic?
(New – 4/13/20)

The COA supports activities that promote wellness for program administrators, faculty, SRNAs, and others. The AANA has a webpage identifying resources for COVID-19 Well-being for CRNAs and SRNAs. Categories include mental, emotional and physical well-being, and more. Additional resources are added periodically.