10-22: Eligible Career Pathway Programs - Questions and Answers

Posted Date: October 22, 2015

Author:  Lynn B. Mahaffie, Deputy Assistant Secretary for Policy, Planning, and Innovation, Office of Postsecondary Education

Subject: Eligible Career Pathway Programs - Questions and Answers

In Dear Colleague Letter GEN-15-09 published on May 22, 2015, we provided institutions with information on changes made to section 484(d) of the Higher Education Act of 1965, as amended (HEA). Those changes allow a student who does not have a high school diploma or its recognized equivalent, or who did not complete a secondary school education in a homeschool setting, to be eligible for Title IV, HEA student assistance through one of the ability-to-benefit (ATB) alternatives, but only if the student is enrolled in an eligible career pathway program. The purpose of this Electronic Announcement is to provide answers to some questions we have received since publication of Dear Colleague Letter GEN-15-09.

Question 1: What is an eligible career pathway program?

Answer 1: As defined in section 484(d)(2) of the HEA, and described in Dear Colleague Letter GEN-15-09, an eligible career pathway program must, among other things, concurrently enroll students in connected adult education and Title IV eligible postsecondary programs and must provide enrolled students with structured course sequences that are articulated and contextualized. The program must also be aligned with the education and skill needs of the regional economy and must have been developed and implemented in collaboration with partners in business, workforce development, and economic development. There could be a variety of different models for eligible career pathway programs that meet the statutory requirements.

We remind institutions of the statutory requirement that an eligible career pathway program must consist of two connected education components – an adult education component integrated with a Title IV eligible postsecondary program component. Each institution must make its own determination, based on the statutory definition, of whether a program is an eligible career pathway program. Institutions must document the basis for such a determination. We describe the requirements for documentation in Answer 2 below, and encourage institutions to review the guidance provided in Dear Colleague Letter GEN-15-09.

Question 2: What documentation must an institution maintain regarding its eligible career pathway program and the students who received Title IV aid under the program?

Answer 2: An institution must maintain documentation that its program meets each of the requirements in the definition of an eligible career pathway program in section 484(d)(2) of the HEA and described in Dear Colleague Letter GEN-15-09. This includes documentation that supports that the institution's eligible career pathway program was developed and implemented in collaboration with partners in business, workforce development, and economic development and that the program is aligned with the education and skill needs of the regional economy.

Also, for each student who received Title IV aid for enrollment in an eligible career pathway program by successfully completing one of the ATB alternatives, the institution must document—

  • The date when the student first enrolled in any eligible Title IV postsecondary program for purposes of determining a student's eligibility for a Regular Pell Grant or Limited Pell Grant as discussed in Dear Colleague Letter GEN-15-09;

  • Evidence that the student successfully completed one of the ATB alternatives; and

  • That the student was concurrently enrolled in both the adult education component and the Title IV eligible postsecondary program component of the eligible career pathway program for the entire time he or she was receiving Title IV aid under this provision.

It is the institution's responsibility to document its compliance with all applicable programmatic and student eligibility requirements.

Question 3: Can the Department further clarify the requirement that the adult education component be "connected" to the Title IV eligible postsecondary program component in an eligible career pathway program?

Answer 3: "Connected" means an integrated service approach that provides students with adult education that is concurrently and contextually aligned with the Title IV eligible postsecondary program.

Question 4: Is the definition of an eligible career pathway program met if the Title IV eligible postsecondary institution has a written agreement with a qualifying adult education program at another Title IV eligible postsecondary institution or with another entity?

Answer 4: This type of agreement will meet the requirement only if the adult education component is integrated with and connected to the Title IV eligible postsecondary program component, as described in Answer 3. A written agreement between entities in and of itself is not sufficient.

Question 5: Is an eligible career pathway program a Gainful Employment (GE) program?

Answer 5: Only the Title IV eligible postsecondary program component of an eligible career pathway program may be a GE program. For example, if a community college has an adult education component that is integrated with a certificate program creating an eligible career pathway program, it is the certificate program that is designated as a GE program and not the eligible career pathway program. Similarly, if a public community college integrates that same adult education component with an associate degree program, the associate degree program is not a GE program because degree programs offered by public institutions (and by private not-for-profit institutions) are not GE programs.

Question 6: Does an eligible career pathway program have to be approved or endorsed by the Department or by the institution's accrediting agency, the State agency that authorizes the institution, or a State workforce agency?

Answer 6: There is no requirement under the HEA that an eligible career pathway program be approved or endorsed by the Department or by an accrediting agency or a State in order to meet the statutory definition. However, institutions may be subject to State laws or regulations regarding eligible career pathway programs or relevant requirements of their accrediting agency(ies). The Department will not be developing a career pathway program approval process, but will evaluate these programs through program reviews and audits.

During any program review or audit of an institution's development and implementation of an eligible career pathway program, the Department will consider whether the institution made a good faith effort to comply with the relevant statutory provisions, as described in Dear Colleague Letter GEN-15-09, this Electronic Announcement, and any other guidance that we provide.

We remind institutions that the Title IV eligible postsecondary program component of an eligible career pathway program must meet all the requirements for Title IV eligibility under 34 CFR 668.8, including that the institution be accredited and have authorization by the State to offer the postsecondary program.

Question 7: What are the requirements for the adult education component of an eligible career pathway program?

Answer 7: As outlined in Dear Colleague Letter GEN-15-09, the adult education component of an eligible career pathway program must include academic instruction and education services below the postsecondary level that increase an individual's ability to—

  • Read, write, and speak in English and perform mathematics or other activities necessary for the student to attain a secondary school diploma or the Recognized equivalent of a high school diploma defined under 34 CFR 600.2 (see also Dear Colleague Letter GEN-14-06);

  • Transition to postsecondary education and training; and

  • Obtain employment.

Question 8: Is each ATB student required to be concurrently enrolled in both adult education and postsecondary coursework throughout the student's enrollment in an eligible career pathway program?

Answer 8: Yes, a student without a high school diploma or its recognized equivalent must remain enrolled in both the adult education component and in the Title IV eligible postsecondary program component throughout the student's enrollment in an eligible career pathway program in order to be eligible for Title IV aid through one of the ATB alternatives. Note that the student must have successfully completed one of the ATB alternatives before he or she is eligible to receive Title IV aid.

Question 9: Is each ATB student required to take coursework from both the adult education component and from the Title IV eligible postsecondary program component in each payment period in order to receive Title IV aid?

Answer 9: For a student to be eligible for Title IV aid after successfully completing one of the ATB alternatives, the student must be concurrently enrolled in both the adult education and the Title IV eligible postsecondary components of the eligible career pathway program and that enrollment must be documented by the institution (see Answers 2 and 8).

However, that does not preclude a student from occasionally being enrolled in just one component of the eligible career pathway program for any particular payment period as long as the institution has evidence that the student has taken coursework in both components throughout the student's enrollment in the eligible career pathway program.

For example, consider a student who took classes in both the adult education component and the Title IV eligible postsecondary program component for the first and second payment periods (e.g., Fall and Spring semesters) of the student's enrollment in the career pathway program, but only classes in the Title IV eligible postsecondary program component for the summer (the third payment period) because no adult education program was offered in the summer term. This student would be eligible to receive Title IV aid for all three payment periods for enrollment in the Title IV eligible postsecondary program component.

Note that as discussed in Dear Colleague Letter GEN-15-09, a student is only eligible for Title IV aid for coursework that is part of the Title IV eligible postsecondary program component. Therefore, a student solely enrolled in adult education coursework during a payment period would not be Title IV eligible for that payment period.

As noted in Dear Colleague Letter GEN-15-09, all Title IV awards are calculated using only the costs and enrollment status related to the postsecondary coursework.

Question 10: What impact does the enrollment of a student in the adult education component of an eligible career pathway program have on the administration of Title IV aid?

Answer 10: It is only the Title IV eligible postsecondary program component that supports a student's eligibility for Title IV aid; and the Title IV regulations and provisions apply only to the Title IV eligible postsecondary program component.

Therefore, when constructing a student's Title IV cost of attendance (COA), only the costs related to the Title IV eligible postsecondary program component can be included. Likewise, only the clock or credit hours of the Title IV eligible postsecondary program component can be used to establish the student's Title IV enrollment status. For the same reason, provisions related to a student's enrollment and withdrawal, and any resultant Return of Title IV Funds calculation and NSLDS enrollment reporting, only apply to the Title IV eligible postsecondary program component of the eligible career pathway program.

Question 11: For determining whether a student enrolled in an eligible career pathway program meets the ATB eligibility criteria, would remedial or developmental coursework fulfill the ATB requirement that the student complete at least 6 hours that are applicable toward a degree or certificate offered by the Title IV eligible postsecondary institution?

Answer 11: No, the requirement is that the 6 credit hours (or 225 clock hours) must be applicable to a degree or other credential offered by the Title IV eligible postsecondary institution. The completion of remedial or developmental coursework does not qualify.

Question 12: When is a student no longer considered to be an ATB student?

Answer 12: A student who gained Title IV eligibility under one of the ATB alternatives is considered to be an ATB student until the student obtains a high school diploma or its recognized equivalent. Once the student receives a high school diploma or its recognized equivalent, the student would no longer be subject to restrictions placed on ATB students, including the requirement that the student continue to be enrolled in the eligible career pathway program. At that time, a student could also enroll in any other Title IV eligible postsecondary program and receive Title IV assistance (assuming all other eligibility requirements are met).

If a student receives a high school diploma or its recognized equivalent while enrolled in an eligible career pathway program and the student had previously received a Limited Pell Grant as described in Dear Colleague Letter GEN-15-09, the student would be eligible for a Regular Pell Grant for the payment period in which the student earned the high school diploma or its recognized equivalent, and would remain eligible for a Regular Pell Grant throughout his/her enrollment in the eligible career pathway program.

 

Publication Date: 10/22/2015


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