ED to Issue Correction to 2012-13 FSA Handbook on ATB Determinations

NASFAA has received a number of member inquiries concerning the status of ability-to-benefit determinations to establish a student’s eligibility for Title IV funds. For students who are or were enrolled in a Title IV-eligible program prior to July 1, 2012, institutions may use one of two methods to establish a student’s ability to benefit from the training or education offered as an alternative to a high school diploma or its equivalent. The student must either pass an approved test, or must successfully complete six credits or 225 clock hours (at their own expense) applicable to a program of study at the institution.

Students who first enroll in a program of study on or after July 1, 2012, will no longer have the option of establishing Title IV eligibility under either ability-to-benefit provision. These provisions were eliminated by the Consolidated Appropriations Act of 2012 (Public Law 112-74). Students will have to either have a high school diploma or its equivalent, or have been home-schooled in accordance with current regulation.

Some confusion has arisen regarding the elimination of the earned hours alternative due to only partially-updated language in the 2012-13 FSA Handbook. It is NASFAA’s understanding that a correction to the Handbook language will be issued. In the meantime, schools should continue to refer to Dear Colleague Letter GEN-12-01, which states:

Public Law 112-74 amended HEA section 484(d) to eliminate Federal student aid eligibility for students without a "certificate of graduation from a school providing secondary education or the recognized equivalent of such a certificate." The law makes an exception for students who have completed a secondary school education in a home school setting that is treated as a home school or private school under State law.

According to the letter, further guidance on implementation details is forthcoming.