High School Diplomas and the Ability-to-Benefit Alternative

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High School Diplomas and the Ability-to-Benefit
Alternative

• Carney McCullough
• U.S. Department of Education

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Todays Agenda

• Student Eligibility
• High School Diploma
• Recognized Equivalent of a High School Diploma
• Homeschool
• Ability-to-Benefit

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Eligible Student (668.32(e))

• Has a high school diploma
• Has the recognized equivalent of a high school
  diploma
• Completed secondary school in a homeschool
  setting
• For students enrolled prior to July 1, 2012,
  demonstrated the ability-to-benefit from the
  education or training

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Administrative Capability (668.16(p))

• Requires institutions to develop and follow
  procedures to evaluate the validity of a
  students high school diploma if the institution
  or the Secretary has reason to believe that the
  diploma is not valid or was not obtained from an
  entity that provides secondary school education

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High School Diploma (668.32(e)(1))

• Additional question on the FAFSA requesting the
  name, city, and state of high school
• Dropdown box on FOTW with a list of high schools
• No requirement to collect high school diplomas
• No requirement to compare with information
  collect by the Admissions Office
• No comments related to high school completion
  status on the ISIR for 2012-13

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High School Diploma

• Receipt of diploma is a student eligibility item
• Procedure is an institutional requirement, not a
  verification item
• Action required if the student or Secretary has
  concerns about the validity of a students diploma

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High School Diploma

• When would an institution have reason to believe
  that there is an issue with the students high
  school diploma?
• ED tells you
• The financial aid office knows there is a problem
• Another office at the institution, such as
  admissions, has identified an issue

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High School Diploma

• List used to populate FAFSA drop-down box
• No ED list of bad schools

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High School Diploma

• Resources
• State Department of Education in the state in
  which high school is located
• Companies that determine validity of foreign high
  school diplomas
• Other institutions of higher education
• Membership organizations that evaluate the
  validity of high schools

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High School Diploma

• Issues with prior year awards
• Dear Colleague letter GEN-12-03

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High School Diploma

• Information for School Participation Team
• Details of determination that high school diploma
  is not valid
• Information about circumstances under which
  initially accepted high school completion status
• Payment period(s) when aid was received
• Types and amounts of aid received by payment
  period
• If credible information that the student may have
  engaged in fraud, report to the Office of
  Inspector General.

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Recognized Equivalent of a High School Diploma
(600.2, 668.32(e)(1))

• A General Education Development Certificate
  (GED)
• A State certificate received by a student after
  the student has passed a State-authorized
  examination that the State recognizes as the
  equivalent of a high school diploma
• An academic transcript of a student who has
  successfully completed at least a two-year
  program that is acceptable for full credit toward
  a bachelors degree or

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Recognized Equivalent of a High School Diploma

• For a person who is seeking enrollment in an
  educational program that leads to at least an
  associate degree or its equivalent and who has
  not completed high school, but who excelled
  academically in high school, documentation that
  the student excelled academically in high school
  and has met the formalized, written policies of
  that postsecondary institution for admitting such
  students

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Homeschool (668.32(e)(4))

• Has completed a secondary school education in a
  homeschool setting that is treated as a
  homeschool or private school under State law and
  has obtained a homeschool completion credential,
  or
• If State law does not require a homeschool
  credential, has completed a secondary school
  education in a homeschool setting that qualifies
  as an exemption from compulsory school attendance
  requirements under State law

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Ability-to-Benefit (668.32(e)(2), (3), (5))

• For students enrolled in a Title IV eligible
  program prior to July 1, 2012, demonstrates the
  ability-to-benefit by
• Passing an independently administered, Department
  of Education approved ATB test

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Ability-to-Benefit

• Completing at least six credit hours, or the
  equivalent coursework (225 clock hours), that are
  applicable toward a degree or certificate offered
  by the postsecondary institution, or
• Completing a State process approved by the
  Secretary of Education. NOTE No State process
  has ever been submitted for the Secretarys
  approval

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Ability-to-Benefit

• For students who first enroll in a program of
  study on or after July 1, 2012, and who do not
  have a high school diploma or its recognized
  equivalent or who have not completed a homeschool
  program, the Consolidated Appropriations Act,
  2012 (Public Law 112-74) eliminates the
  ability-to-benefit (ATB) alternatives.
• See Dear Colleague letters GEN-12-01 and
  GEN-12-09.

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Ability-to-Benefit Grandfathering Test

• Question 1
• Did or will the student attend an eligible
  program at any Title IV institution prior to July
  1, 2012?
• IF YES The student may use any of the ATB
  alternatives to become eligible for Title IV, HEA
  student assistance.
• IF NO Continue to Question 2.

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Ability-to-Benefit Grandfathering Test

• Question 2
• Did the student, prior to July 1, 2012,
  officially register at a Title IV institution,
  and is the student scheduled to attend a eligible
  program?
• IF YES The student may use any of the ATB
  alternatives to become eligible for Title IV, HEA
  student assistance.
• IF NO The student may not use the ATB
  alternatives to become eligible for Title IV, HEA
  student assistance.

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Ability-to-Benefit Grandfathering Test

• If the response to either question is YES, the
  student is eligible for Title IV aid if
• Met one of the ATB alternatives prior to July 1,
  2012
• Establishes eligibility under one of the ATB
  alternatives on or after July 1, 2012

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Ability-to-Benefit Scenarios

1. The student attended an eligible program prior to
   July 1, 2012, did not receive Title IV aid, and
   will continue to attend the same institution.
2. The student attended an eligible program prior to
   July 1, 2012, ceased attendance for a period of
   time, and will attend an eligible program at the
   same institution after July 1, 2012.

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Ability-to-Benefit Scenarios

1. The student attended an eligible program prior to
   July 1, 2012, and will begin attendance in an
   eligible program at a different institution after
   July 1, 2012. The institution must document the
   students attendance at the prior institution.

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Ability-to-Benefit Scenarios

1. The student attended an eligible program prior to
   July 1, 2012, ceased attendance for a period of
   time, and will attend a different eligible
   program at a different institution. The
   institution must document the students
   attendance at the prior institution.

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Ability-to-Benefit Scenarios

• The student did not previously attend an eligible
  program but, prior to July 1, 2012, registered
  and is scheduled to attend an eligible program.
  NOTE The exception is only available for
  attendance in a program for which the student
  officially registered prior to July 1, 2012.

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Ability-to-Benefit Scenarios

• Students in these scenarios may establish Title
  IV eligibility by satisfying any of the ATB
  alternatives.

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Questions?
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Contact Information

• Carney McCullough
• Carney.McCullough_at_ed.gov
• 202-502-7639