Institutions with a Prison Education Program (PEP) now have federal guidance for post-program approval and reporting documentation.
In a September 21 Electronic Announcement, the Department of Education (the Department) outlined information addressing “Post Approval Guidance” and “Reporting Guidance” for institutions of higher education.
Post Approval Guidance
When the Department approves a PEP, the institution is sent an approval letter or approval notice and an Eligibility and Certification Approval Report (ECAR) that lists the PEP and its initial approval date. These approval documents should then be provided by the institution to their accrediting agency and the oversight entity. The approval letter will inform them of when the Best Interest Determination time frame starts and of their respective responsibilities. More information about Best Interest Determinations can be found in GEN-26-23.
Reporting Guidance
Pell Grant eligibility was restored for confined or incarcerated students who enroll in an eligible PEP through the FAFSA Simplification Act. An overview of the requirements can be found in Dear Colleague Letter GEN-23-05 and in the federal regulations under 34 CFR 668.
Institutions with a PEP program must annually report to the Department specific information about each student receiving Pell Grant, including additional information about the PEP. The required reporting includes:
- Institutions must provide information about every Pell Grant awarded to a student enrolled in a PEP by using a template through the Common Origination and Disbursement (COD) website. When completing the report, institutions link additional information about the student receiving a Pell Grant to the data reported in COD, which includes data from the FAFSA form. Both the template and the method to submit the completed report are available in COD.
- Institutions must complete a school survey that collects information about the schools’ PEP(s) offerings, covering topics such as the challenges the institution faced when offering its PEP, student transfer and release data, the types of services being provided to incarcerated students, and how satisfactorily the “best interests” of incarcerated students are being monitored. ED will contact PEP institutions with instructions to access the institution survey portion of the required annual PEP reporting.
The COD report and the survey for students enrolled in a PEPs in the 2025–26 award year must be completed by December 31, 2026.
For future award years, the Department is exploring streamlining the reporting into one system and process and will announce any changes when it is available.
The Department offers several resources for schools:
- Prison Education Program Topics page on the Knowledge Center
- a seven-section, on-demand course on prison education programs available in the FSA Training Center
- Application for Approval to Participate in the Federal Student Financial Aid Programs (E-App)
- Prison Education Programs Questions and Answers
Questions about PEP reporting need to be sent to PEP@ed.gov.
