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Session 29
Experimental Sites
Michael Cagle, Craig Munier, and David Musser | Dec. 2015
U.S. Department of Education
2015 FSA Training Conference for Financial Aid Professionals
Experimental Sites Initiative (ESI)
•
Authority under Section 487A(b) Higher Education Act of
1965, as amended
• Tests the effectiveness of statutory and regulatory
flexibility for participating institutions disbursing Title IV
student aid
• Provides waivers of specific statutory and/or regulatory
requirements
• Intended to yield data that will inform decisions about
changes to regulations and statute
2
Experimental Sites Team
Name
Email
Phone
Location
Michael Cagle
[email protected]
206-615-2586
Seattle
Warren Farr
[email protected]
202-377-4380
DC/UCP
Holly Langer-Evans
[email protected]
617-289-0136
Boston
Craig Munier
[email protected]
202-377-4435
DC/UCP
David Rhodes
[email protected]
202-377-3066
DC/UCP
Anne Tuccillo
[email protected]
202-377-4378
DC/UCP
ESI Mailbox
[email protected]
3
Current Experiments Announced in 2011
•
•
•
Federal Register Notice – 10/27/11
• Pell for Students with Bachelor’s Degrees
• Pell for Short-Term Training Programs
For both experiments, otherwise eligible students will be
randomly selected to receive Pell Grants
Still opportunity to participate - send e-mail to:
[email protected]
4
Pell for Students with Bachelor’s Degrees
Current Rules
•
Generally, a student who has earned
a bachelor’s degree is not eligible for
Pell Grant funds
5
Experiment
•
An otherwise-eligible student who
has a bachelor’s degree, but is
unemployed or under-employed,
may be eligible Pell Grant funds for
enrollment in eligible vocational or
career programs
Pell for Students with Bachelor’s Degrees
Waivers
Law/Regulation
Description
HEA section 401(c)(1) and 34 CFR
668.32(c)(2)(i)(A)
Excludes students who have earned a
bachelor’s degree from receiving Pell
Grant funding
Limits eligibility for Pell Grants to
students who have not earned their
first bachelor’s degree
34 CFR 690.6(a)
6
Pell for Students with Bachelor’s Degrees
Experiment Requirements:
• Students must be otherwise eligible for Pell Grants and
unemployed or under-employed
• Enrollment must be in a vocational or career program
that leads to a credential awarded by your institution
• Program’s length must be one-year or less, but meet
normal minimum length requirements
• Student must be able to complete the program in no
more than two years
7
Pell for Short-Term Training Programs
Current Rules
•
Students may be eligible for Pell
Grant funds in an educational
program if the program is:
– At least 15 weeks of instructional
time in duration; and
– Includes at least 600 clock hours,
16 semester hours, or 24 quarter
hours
8
Experiment
•
Students may be eligible for Pell
Grants in short-term training
programs if the program is:
– At least 8 weeks of instructional
time in duration; and
– Includes at least 150 clock hours,
4 semester hours, or 6 quarter
hours
Pell for Short-Term Training Programs
Waivers
Law/Regulation
Description
HEA section 481(b)(1)(A)
Sets the minimum timeframes for a Pell
Grant eligible program
34 CFR 668.8(d)(1)(i) and (ii)
Establishes the timeframes for Title IVeligible programs
9
Pell for Short-Term Training Programs
Experiment requirements:
• Students must be otherwise eligible for Pell Grants
• Program must be least 8 weeks of instructional time in
duration and include at least 150 clock hours, 4
semester credit hours or 6 quarter credit hours
• Program must lead to a certificate, degree, or credential
awarded by your institution
10
Current Experiments Announced in 2014
•
•
Federal Register Notice – 7/31/14
• Prior Learning Assessment (PLA)
• Limited Direct Assessment (LDA)
• Competency-Based Education (CBE)
• Federal Work-Study (FWS) for Near-Peer Counseling
Still opportunity to participate - send e-mail to:
[email protected]
11
Prior Learning Assessment
Current Rules
•
Costs for prior learning assessments
may not be included in COA
Time and effort spent preparing for
prior learning assessments may not
be included in a student’s enrollment
status
•
12
Experiment
•
•
COA can include reasonable costs
incurred by a student for assessments
of prior learning
Federal Pell Grant enrollment status
may include up to three credit hours
associated with a student’s efforts to
prepare materials for a prior learning
assessment
– Example: Preparing for a
portfolio assessment
Prior Learning Assessment
Waivers
Law/Regulation
Description
HEA Section 472
Establishes types of expenses that may be
considered when determining a student’s
financial need
34 CFR 668.2
Definition of enrollment status
34 CFR 600.2
Definition of “credit hour”
34 CFR 668.10(f)
Prohibition on the use of Title IV funds for
PLA in direct assessment programs
13
Prior Learning Assessment
Experiment Requirements:
• The institution must include the cost of prior learning
assessments in students’ cost of attendance
• The institutions must provide academic credit when a
student successfully demonstrates prior learning through
an assessment that is included in the experiment
14
Limited Direct Assessment
Current Rules
•
Must use direct assessment for the
entire direct assessment program,
not a combination of direct
assessment and traditional credit
hours or clock hours
May not provide remedial
coursework offered using direct
assessment
•
15
Experiment
•
•
Programs offering a combination of
direct assessment and credit/clock
hours are allowed
An institution may include remedial
coursework offered in credit hours or
using direct assessment in a student’s
enrollment status
Limited Direct Assessment
Waivers
Law/Regulation
Description
HEA section 481(b)(4) and 34 668.10 (a)(1)
Requires that a direct assessment program
use direct assessment for the entire
program
34 CFR 668.10(g)(2)
Prohibits the payment of Title IV aid for
remedial coursework offered using direct
assessment
16
Limited Direct Assessment
Experiment Requirements:
• The institution must offer an approved direct
assessment program including at least one course or
competency that also uses credit or clock hours
AND/OR
• The institution must offer at least one remedial course or
competency using direct assessment
17
Competency-Based Education
•
The Competency-Based Experiment provides three
separate sets of waivers that institutions may choose from
1. Split Disbursement (July 2014 Federal Register)
2. Satisfactory Academic Progress ONLY (November 2015 Federal Register)
3. Subscription Period Disbursement (November 2015 Federal Register)
18
Competency-Based Education
Current Rules
•
Disbursements for direct costs and
indirect costs made at same time
Disbursements for a term-based
program are made each term
Disbursements for a nonterm
program are made when the student
completes both 50% of credits and
weeks in the academic year
•
•
19
Split Disbursement Waivers
•
•
•
Disbursements for direct and indirect
costs may occur at different times
Disbursements may be made for
direct costs when competencies have
been mastered
Disbursements for indirect costs must
be made at regular intervals
Competency-Based Education
Current Rules
•
Term program: Each term is a
payment period
Nonterm program: A payment period
is the time it takes for the student to
complete 50% of the credits in the
academic year and 50% of the weeks
in the academic year
•
20
Split Disbursement Waivers
•
•
Two types of payment periods: direct
cost payment periods and indirect
cost payment periods
Payment periods are no more than
25% of the defined Title IV academic
year component
Competency-Based Education
Current Rules
•
Must check a student’s satisfactory
academic progress once annually but
can check more often
Quantitative evaluation determines
whether a student is on pace to
complete within 150% of normal
time, and is calculated by dividing
credits completed over credits
attempted
•
21
Split Disbursement Waivers
•
•
Must check a student’s satisfactory
academic progress in a CBE program
at least once when the student
finishes the weeks in the program’s
Title IV academic year, but can check
more often
Quantitative evaluation is whether
student is on pace to complete the
program within 150% of the normal
time over a given calendar period
Competency-Based Education
Current Rules
•
R2T4 calculation is required if a
student withdraws during the
payment period
Split Disbursement Waivers
•
•
22
R2T4 calculations are not required for
CBE programs included in the
experiment
Institutions must pay grant funds or
notify students of loan funds that
could have been disbursed as of the
withdrawal date
Competency-Based Education
Waivers (Split Disbursement)
Law/Regulation
Description
34 CFR 668.4(c)
Definition of a payment period
34 CFR 690.63(e)(2)
Calculation of a Federal Pell Grant for a
payment period
34 CFR 685.303 (e)(2) and (3)
Annual loan limits for Direct Loans
23
Competency-Based Education
Waivers (Split Disbursement)
Law/Regulation
Description
34 CFR 674.16(b)(3), 34 CFR 676.16(a)(3),
34 CFR 686.33(a), 34 CFR 690.76(a)
HEA Section 428G(a)(2) and
34 CFR 685.303(d)(3)(ii)(B)
HEA section 484 B and 34 CFR 668.22
[NOT exempt from 34 CFR 668.22(a)(2) and
34 CFR 668.22(a)(6)]
Requirements for frequency of
disbursements for grants and Perkins Loans
Requirements for determining
disbursement dates for Direct Loans
Treatment of Title IV funds when a student
withdraws
24
Competency-Based Education
Waivers (Split Disbursement)
Law/Regulation
Description
HEA Section 484 (c) and 34 CFR 668.34
(a)(3)(ii),(a)(5)(ii), and (b)
Requirements for satisfactory academic
progress evaluations
25
Competency-Based Education
Current Rules
•
Must check a student’s satisfactory
academic progress once annually but
can check more often
Quantitative evaluation determines
whether a student is on pace to
complete within 150% of normal
time, and is calculated by dividing
credits completed over credits
attempted
•
26
SAP Waivers Only
•
•
Must check a student’s satisfactory
academic progress in a CBE program
at least once when the student
finishes the weeks in the program’s
Title IV academic year, but can check
more often
Quantitative evaluation is whether
student is on pace to complete the
program within 150% of the normal
time over a given calendar period
Competency-Based Education
Waivers (SAP Waivers Only)
Law/Regulation
Description
HEA Section 484 (c) and 34 CFR 668.34
(a)(3)(ii),(a)(5)(ii), and (b)
Requirements for satisfactory academic
progress evaluations
27
Competency-Based Education
Current Rules
•
All classes in a term must begin and
end within the established term
dates
Enrollment status for a term
determined using all the classes in
which a student enrolls during that
term
•
28
Subscription Period Waivers
•
•
•
Subscription periods are considered
standard or nonstandard "terms"
Competencies in a term may begin
before the term begins
A student's enrollment status is
determined using all the
competencies a student is expected
to complete during the term
Competency-Based Education
Current Rules
•
Disbursements for a term-based
program are made each term
Direct Loan disbursements must be
made in "substantially equal"
allotments
•
Subscription Period Waivers
•
•
29
Disbursements are made each
subscription period in accordance
with rules for disbursement for the
type of term the institution uses
(standard and nonstandard)
Direct Loan disbursements are
prorated based on length of payment
period in the same way as Pell or
TEACH Grants
Competency-Based Education
Current Rules
•
Must check once annually but can
check more often
Quantitative evaluation determines
whether a student is on pace to
complete within 150% of normal
time, and is calculated by dividing
credits completed over credits
attempted
•
30
Subscription Period Waivers
•
•
•
Must check satisfactory academic
progress at least once each term
Each evaluation must include a review
of the student's progress:
– cumulatively
– within the prior term
Quantitative evaluation is whether
student is on pace to complete the
program within 150% of normal time
Competency-Based Education
Waivers (Subscription Period Disbursement)
Law/Regulation
Description
34 CFR 668.4(a) and (b)
Definition of a standard or nonstandard
term payment period
HEA Section 484 (c) and 34 CFR 668.34
(a)(3)(ii),(a)(5)(ii), and (b)
Requirements for satisfactory academic
progress evaluations
34 CFR 685.303(d)(5)
Proration of Direct Loans based on length of
payment period
34 CFR 690.80(b)(2)(i)
Calculation of enrollment status for Pell
31
Competency-Based Education
Experiment requirements:
• The institution must provide at least one program which is
offered through competency-based education for at least
one academic year
• Competency-based education programs included in the
experiment must be approved or recognized by an
accrediting agency as a competency-based education
program
32
Federal Work-Study
Current Rules
•
Except under limited circumstances,
the Federal Share of compensation
paid to students employed under the
FWS Program may not exceed 75%
33
Experiment
•
The “matching” share of the FWS
compensation will be reduced or
eliminated for near-peer counselors,
allowing 100% of Federal funds to
provide FWS compensation to those
students
Federal Work-Study
Waivers
Law/Regulation
Description
HEA section 443(b)(5) and 34 CFR 675.26 (a) Requirement that the Federal share
of compensation paid to an FWS
student may not exceed 75 percent
34
Federal Work-Study
Experiment requirements:
• Students must be otherwise eligible for FWS
• The institution must provide FWS compensation to
students for work as near-peer counselors
• The institution must ensure that near-peer counselors
are knowledgeable and either experienced in or trained
in relevant counseling techniques
• Activities, information, and initiatives must be targeted to
the needs of high school students
35
New Experiments Announced in 2015
•
Second Chance Pell
• Federal Register Notice – 8/3/15
• Educational Quality through Innovative Partnerships (EQUIP)
• Federal Register Notice – 10/15/15
• Dual Enrollment
• Federal Register Notice – 11/3/15
36
New Experiments Announced in 2015
•
Priority application period open for Dual Enrollment
experiment until February 1, 2016
•
Still opportunity to participate in all experiments announced
in 2015 - send e-mail to: [email protected]
37
Second Chance Pell
Current Rules
•
Students incarcerated in Federal or
State penal institutions are not
eligible for Federal Pell Grant funds
38
Experiment
•
Students incarcerated in Federal or
State penal institutions, are eligible
for Pell Grant funds
Second Chance Pell
Waivers
Law/Regulation
Description
Section 401(b)(6) of the HEA and 34 CFR
668.32(c)(2)(ii)
Provides that students who are incarcerated
in a Federal or State penal institution are
not eligible to receive Federal Pell Grant
funds
39
Second Chance Pell
Experiment requirements:
• The institution must:
• Partner with Federal/State correctional facilities to offer
Title IV eligible programs to incarcerated students
• Work with the partnering correctional facilities to
encourage interested students to submit a FAFSA
40
Second Chance Pell
Experiment requirements (continued):
• The institution must:
• Offer students the opportunity to continue their
enrollment in the academic program if the student is
released from prison prior to program completion
• Inform students of the academic and financial options
available if they are not able to complete the academic
program while incarcerated
41
Second Chance Pell
Experiment requirements (continued):
• The institution must:
• Only enroll students in postsecondary education and
training programs that prepare them for high-demand
occupations from which they are not legally barred from
entering due to restrictions on formerly incarcerated
individuals obtaining any necessary licenses or
certifications for those occupations
42
Second Chance Pell
Experiment requirements (continued):
• The institution must:
• Disclose to interested students and to the Department
information about any portions of a program of study
that, by design, cannot be completed while students are
incarcerated, as well as the options available for
incarcerated students to complete any remaining
program requirements post-release
43
Second Chance Pell
Experiment requirements (continued):
•
44
Prisoners must be eligible for release and priority given
to prisoners who are likely to be released within five
years of enrollment in the educational program
EQUIP
Current Rules
•
An ineligible institution or
organization (referred to as a nontraditional provider) is limited to
providing less than 50 percent of the
content and instruction of a title IV
eligible educational program
45
Experiment
•
Participating institutions may provide
Title IV aid to otherwise eligible
students pursuing a program of study
for which 50 percent or more of the
content and instruction is offered by
one or more Title IV-ineligible
organizations (non-traditional
providers)
EQUIP
Current Rules
•
Generally, a Title IV-eligible
educational program must:
– Be at least 15 weeks of
instructional time in duration;
and
– Include at least 600 clock hours,
16 semester hours, or 24 quarter
hours
46
Experiment
•
A program included in the EQUIP
experiment must:
– Be least 8 weeks of instructional
time in duration; and
– Include at least 450 clock hours,
12 semester hours, or 18 quarter
hours
EQUIP
Current Rules
•
Must check a student’s satisfactory
academic progress once annually but
can check more often
Quantitative evaluation determines
whether a student is on pace to
complete within 150% of normal
time, and is calculated by dividing
credits completed over credits
attempted
•
47
Experiment
•
•
Must check a student’s satisfactory
academic progress in an approved
program at least once in each Title IV
academic year, but can check more
often
Quantitative evaluation is whether
student is on pace to complete the
program within 150% of the normal
time over a given calendar period
EQUIP
Waivers
Law/Regulation
Description
34 CFR 668.8(a)
Requires that an eligible program be
provided by the participating institution
34 CFR 668.5(c)(3)
Restricts the amount of an eligible program
that may be provided by an ineligible
institution or organization
48
EQUIP
Waivers
Law/Regulation
Description
Section 481(b)(1)(A) of the HEA and 34 CFR
668.8(d)(1)(i) and (ii)
Sets the minimum timeframes for a Pell
Grant eligible program and establishes the
timeframes for eligible programs.
HEA Section 484 (c) and 34 CFR 668.34
(a)(3)(ii),(a)(5)(ii), and (b)
Requirements for satisfactory academic
progress evaluations
49
EQUIP
Experiment requirements:
• The institution must create one or more coherent
programs of study using educational content from one
or more non-traditional providers of postsecondary
education that are not Title IV-eligible
• Fifty percent or more of each program included in the
experiment must be provided by one or more nontraditional providers
50
EQUIP
Experiment requirements (continued):
• Programs included in the experiment must be reviewed,
approved, and monitored by an independent quality
assurance entity (QAE), and must also be included in
the institution’s grant of accreditation and State
authorization
• Programs not meeting the standards of the Department,
the institution, the QAE, or the institution’s accrediting
agency must be improved or terminated
51
EQUIP
Experiment requirements (continued):
• Programs under the experiment must meet requirements
for Title IV eligibility, including leading to a degree or
other recognized credential and meeting gainful
employment requirements, if applicable
• The institution must choose to provide only Pell Grants
to eligible students, or Pell Grants, campus-based aid,
and undergraduate Direct Loans
52
EQUIP
Experiment requirements (continued):
• The institution must clearly disclose to prospective
students information about the experimental nature of
the programs, the possibility of termination of the
programs, and how a teach-out could be conducted
• For those programs in which students will have access
to Federal loans, an institution must submit plans
describing how students and taxpayers will be
protected in the event the program is terminated
53
Dual Enrollment
Current Rules
•
A student may not receive title IV
assistance, including Federal Pell
Grants, if the student is, in addition
to being enrolled in an eligible
postsecondary educational program,
also enrolled in secondary school
A student must have a high school
diploma or its recognized equivalent
in order to receive title IV aid
•
54
Experiment
•
•
An otherwise-eligible student who is
enrolled in both secondary school
and an eligible postsecondary
program may receive a Pell Grant
An otherwise-eligible student
enrolled in both secondary school
and an eligible postsecondary
program does not need to have a
high school diploma or its recognized
equivalent to receive Pell Grant funds
Dual Enrollment
Waivers
Law/Regulation
Description
Section 484(a)(1) of the HEA and 34 CFR
668.32(b)
Prohibits a student who is enrolled in
secondary school from receiving funds
under the Federal Pell Grant program
Section 484(d) of the HEA and 34 CFR
668.32(e)
Requires that a student have a high school
diploma, or its recognized equivalent, to be
eligible for Federal Pell Grant funds
55
Dual Enrollment
Experiment requirements
• The institution must:
• Require dually enrolled students to enroll in a Title IVeligible postsecondary program as regular students
• Offer students the opportunity to earn at least 12
postsecondary credit hours while dually enrolled
• Ensure that students meet relevant requirements for
dual enrollment (e.g. GPA, placement tests, etc.)
56
Dual Enrollment
Experiment requirements (continued)
• The institution must:
• Prohibit the use of Federal Pell Grant funds for
remedial coursework taken by dually enrolled students
• Provide appropriate student support services, such as
academic tutoring, high school to college transition
support, guidance counseling, or comparable services
57
Dual Enrollment
Experiment requirements (continued)
• The institution must:
• Provide assistance completing the Free Application for
Federal Student Aid (FAFSA). This assistance may be
provided by the public secondary school, the
institution, the LEA, or by another entity
58
Dual Enrollment
Experiment requirements (continued)
• The institution must:
• Ensure that after all Federal and non-Federal
resources have been applied to student charges,
students are not responsible for any remaining
institutional charges as a result of dually enrolling
59
Dual Enrollment
Experiment requirements (continued)
• The institution must:
• Ensure that Federal Pell Grants made available to
students to enroll in programs through this experiment
do not supplant public and institutional sources of
funding for the institution’s dual enrollment
arrangement(s)
60
Evaluation and Reporting
The Department’s evaluation of the experiment will include:
Information Type
61
Possible Data Sources
Institution




Integrated Postsecondary Education Data System (IPEDS)
Institutional Experimental Site Survey and Narrative Descriptions
Common Origination and Disbursement (COD)
National Student Loan Data System (NSLDS)
Program(s)

Institutional Experimental Site Survey and Narrative Descriptions
Students




Institutional Student Information Record (ISIR) Data
Common Origination and Disbursement (COD)
National Student Loan Data System (NSLDS)
Institutional Experimental Site Survey and Narrative Descriptions
How to Apply
Federal Register
• ESI Web Site: ExperimentalSites.ed.gov
Submit Letter of Interest
• Email: [email protected]
62
Selection Process
Review and Screening
Past Compliance
Cross Section of Institutions
Institution participates if…
ED sends invitation to
participate from
[email protected]
63
Institution accepts
invitation
Institution and ED sign
amended PPA
Experimental Sites Initiative Website
https://experimentalsites.ed.gov
64
QUESTIONS?
65