As the focus on the value of career training increases nationwide, the Department is reminding financial aid offices about exceptions to the ability-to-benefit requirements.
Students who otherwise might not be eligible for financial aid because of the ability-to-benefit standards, may be eligible for financial aid in specific career programs, but only if the program has been approved by the Department of Education. The Department recently published a reminder of the process for applying for approval of eligible career pathway programs (ECPP) for use with Ability to Benefit (ATB) at Title IV-eligible institutions. The guidance can be used in conjunction with Dear Colleague Letter GEN-24-08 that was published on June 12, 2024.
The Higher Education Act allows a student who does not have a high school diploma, recognized equivalent, or completes their education in a home school setting to be eligible for Title IV aid through one of the ATB alternatives if the student enrolls in an eligible career pathway program (ECPP).
Students who enroll in an ECPP may be eligible for federal financial aid if they meet one of the following ATB alternatives:
- Pass an independently administered U.S. Department of Education approved ATB test;
- Complete at least six credit hours or 225 clock hours that apply toward a degree or certificate offered by the institution: or
- Complete a state process approved by the Secretary of Education.
Regulations effective July 1, 2024, outlined new requirements for ECPPs that are used to establish student eligibility for federal financial aid. Institutions that wish to offer an ECPP must apply for approval of at least one Career Pathway Program (CPP).
If an institution offered one or more Ability to Benefit Career Pathway Programs prior to July 1, 2024, they must apply to have one of the CPPs certified as eligible for Title IV purposes by the earlier of:
- The submission of any update the institution makes to the Electronic Eligibility Application (E-App) on or after January 1, 2025; or
- The submission of the institution’s recertification application on or after January 1, 2025.
If an institution did not offer an Ability to Benefit Career Pathway Program prior to July 1, 2024, they must submit an E-App with supporting documentation and receive approval before awarding Title IV aid to prospective students.
In order to update the E-App to request ECPP approval, the institution must answer two questions under section #8 – Ability to Benefit. These questions include:
- Do you use an ability to benefit test for students who do not have a high school diploma or its recognized equivalent?
- Do you admit and enroll students through an eligible career pathway program?
The Electronic Announcement includes additional details about the questions. The Department of Education advises institutions with questions about the approval process for ECPPs to contact their School Participation Division. Contact information can be found on the Federal Student Aid’s Partner Connect website.
