FAQS FOR COLLEGES

The Consolidated and Further Continuing Appropriations Act of 2015 reopened the door to opportunity in postsecondary education. This ATB provision has the potential to increase opportunities for many individuals. Education is critical to social and economic development and has a profound impact on population health. It is for this reason many schools have chosen to serve this population in support of their community and those who seek career advancement and opportunity. Other schools serve this population with great success. Serving this sector increases program and institutional enrollment population.

On May 22, 2015, the DOE issued a Dear Colleague Letter (DCL) ID: Gen15-09 giving guidance about Title IV eligibility for students without a valid high school diploma who are enrolled in Eligible Career Pathways Program (ECPP). This letter outlines the requirements adult students without a high school diploma must meet before enrolling in an ECPP program.

Yes.

Non degree programs that do not require a state or national certification or licensure exam are generally eligible, but must be researched to determine their specific requirements. For example, a Licensed Practical Nurse program is not eligible.

If licensure/certification is REQUIRED for employment in a particular field, there is a great likelihood that program may not be eligible for ECPP since a HS diploma or GED would be required to meet the licensure requirements. (Every program should be carefully reviewed within each state and with accreditation requirements prior to beginning to enroll as an ECPP program). Popular eligible programs include (but are not limited to):

• Medical Assisting
• Dental Assisting
• Business Office Administration
• Computer Systems Technician
• Medical Office and Billing
• Cosmetology
• Heating, Vacuum and Air Conditioning

There are seven components, all of which require a thorough understanding and need to be implemented through policy and practice. Program requirements include the following:

1. Concurrently enrolls students in connected adult education and eligible postsecondary programs.
2. Provides students with the counseling and supportive services to identify and attain academic and career goals.
3. Provides structured course sequences that (a) are articulated and contextualized and (b) allow students to advance to higher levels of education and employment.
4. Provides opportunities for acceleration for students to attain recognized postsecondary credentials, including degrees, industry relevant certifications, and certificates of completion of apprenticeship programs.
5. Is organized to meet the needs of adults.
6. Is aligned with the educational and skill needs of the regional economy.
7. Has been developed and implemented in collaboration with partners in business, workforce development and economic development.

The Adult Education High School Diploma Program is NOT paid for with Title IV (DOE) funds. It is paid for through an arrangement between the postsecondary institution and the adult education provider.

If a student enrolled in an ECPP is eligible for Title IV funds, those funds may qualify to pay for the vocational training (post-secondary only) portion or portions of the program.

Students who are otherwise unable to be trained for key vocational careers are now eligible to do so and gain employment upon successful completion of their program. The ECPP student matriculates with the other students in their vocational training so, there is no increased cost to the institution for that portion of the training other than required supplies or instructional wages when class sizes grow.

Transparency. There are a number of Due Diligence practices that can be utilized to minimize risk and to ensure that your vocational schools are delivering the ECPP in a manner that demonstrates compliance with the seven (7) components outlined above. Exploiting Articulating Due Diligence in by documenting, through policy and practice, each of those components is essential.

Yes. The Consolidated and Further Continuing Appropriates Act of 2015 (section 484(d) HEA) allows colleges/schools again to enroll students who do not have a high school diploma (or recognized equivalent), to be eligible for Title IV aid through ability to benefit (ATB) alternatives, but ONLY if the student is enrolled in an "eligible career pathway program”.

Your institution would pay for the cost of C4L services. A minimal expense incurred for the opportunity to serve the population of students/individuals that seek a postsecondary population but do not have a HS diploma or GED.

Yes. Just like you had ATB students take an independently administered entrance exam prior to July 2012.

There is no requirement under the HEA that an Eligible Career Pathway Program must be approved or endorsed by the USDOE, accreditor or state agency however; institutions may be subject to state laws, regulations or relevant requirements of their accrediting agency.

Serving ECPP students is no different than serving students that enroll at your institution that have completed their HS diploma or GED. Similar to all oversight agency regulations, your organization must follow standards. C4L provides support in building sound policies and documented processes to ensure compliance.

To be eligible for federal student financial aid a student must meet all of the following: • Be enrolled in an eligible career pathway program (Ability to Benefit, ATB) • Be enrolled in an eligible degree or certificate program • Have a valid Social Security number • Be a U.S. Citizen or Eligible Non-citizen • Not be in default on a federal student loan or owe a refund on a federal grant and pass an independently administered entrance test.