High School Diplomas and the Ability-to-Benefit Alternative Carney McCullough U.S. Department of Education 1

Today’s Agenda Student Eligibility High School Diploma Recognized Equivalent of a High School Diploma Homeschool Ability-to-Benefit 2

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 3

Administrative Capability (§668.16(p)) Requires institutions to develop and follow procedures to evaluate the validity of a student’s 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 4

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

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 student’s diploma 6

High School Diploma When would an institution have reason to believe that there is an issue with the student’s 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 7

High School Diploma List used to populate FAFSA drop-down box No ED list of “bad” schools 8

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 9

High School Diploma Issues with prior year awards Dear Colleague letter GEN

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. 11

Recognized Equivalent of a High School Diploma (§§600.2, (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 bachelor’s degree; or 12

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 13

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 14

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 15

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 Secretary’s approval 16

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 ) eliminates the ability-to-benefit (ATB) alternatives. See Dear Colleague letters GEN and GEN

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. 18

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. 19

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,

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,

Ability-to-Benefit – Scenarios 3.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, The institution must document the student’s attendance at the prior institution. 22

Ability-to-Benefit – Scenarios 4.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 student’s attendance at the prior institution. 23

Ability-to-Benefit – Scenarios 5.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,

Ability-to-Benefit – Scenarios Students in these scenarios may establish Title IV eligibility by satisfying any of the ATB alternatives. 25

Questions? 26

Contact Information Carney McCullough