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July 24, 2015

bartnickiFederal Training Officer David Bartnicki recently shared these updates:

New Ability-to-Benefit (ATB) Requirements

I spoke with you in the last bulletin about the new DCL GEN-15-09 that the Department released on May 22, 2015. I continue to receive many questions around the new ATB rules, especially if a school has eligible career pathway programs.

First, I want to stress to FAAs that you need to make it clear to your administrators that the new ATB process is VERY different than the old ATB process. Unless a student meets the old ATB rules under the grandfather clause (GEN-12-09), they must be enrolled in an eligible career pathway program to be eligible for TIV under the new ATB criteria. Most schools do NOT have any current eligible career pathway programs or only have a few eligible programs.

Most of your students that do not have HS diplomas or an equivalent will not qualify for TIV aid under ATB because they are not enrolled in an eligible career pathway program. Again, this is a very different ATB process than what was allowed several years ago.

Second, in order to have an eligible career pathway program ALL of the requirements outlined in GEN-15-09 must be met for the program to be an eligible career pathway program. A career pathway program, as defined in section 484(d)(2) of the HEA, is a stand-alone program that contains two specific components within it – connected adult education and an eligible postsecondary program. And remember that it is only the eligible postsecondary program piece that is eligible for TIV aid. Since an eligible career pathway program contains an ineligible piece of adult education coursework, it will never be a TIV approved stand-alone program on your ECAR. This is a very unique and special program developed and designed to assist adult students without HS diplomas progress towards high school completion, postsecondary success and obtain or enhance employment.

Finally, ED updated the approved current ATB tests in a recent electronic announcement dated June 24, 2015, that can be used to support student eligibility for TIV aid. This list is different than what was listed in GEN-15-09. There are currently 2 ATB tests that can be used to support TIV eligibility – CELSA Forms 1 & 2 and ACCUPLACER. As of July 1, 2015, there will be 4 more approved ATB tests – Wonderlic Basic Skills Tests Verbal Forms VS-1/VS-2, Quantitative Forms QS-1/QS-2 both online and paper versions in both English and Spanish. In fact, as of November 1, 2015 only the Spanish Wonderlic tests can be used for Spanish speaking students for ATB purposes. For more test information, including passing scores, publisher contact information and a list of ATB tests no longer approved, please see the 6/24/15 EA.

State Authorization

ED recently posted GEN-15-10, which clearly indicates that the state authorization extensions will end as of June 30, 2015. As of July 1, 2015, all schools that participate in Title IV aid must be properly authorized by a state entity to provide education at a postsecondary level and, where appropriate, the state must have a proper complaint process. If a school’s state authorizing body does not meet ED’s state authorization regulations, a school may be deemed to not be properly authorized and could lose TIV eligibility.

Please note that GEN-15-10 is dealing with a school’s physical location(s) state authorization, not distance education program state authorization. Distance education state authorization at the federal level was vacated in court and it has not been formally updated as of yet. Of course, a school still remains responsible for meeting any and all state requirements.

If state officials have concerns, they should contact Sophia McArdle – (202) 219-7078; If school officials have concerns, they should contact their school participation division (Atlanta, Kansas City or Philadelphia).

GE Programs

If you have not begun submitting your GE program, school and student data to NSLDS, please consider doing so soon. All initial data for the last 6 or 7 years must be received in NSLDS by July 31, 2015. This is extremely important since the data must be received by ED in order for us to properly calculate your GE debt to earning rates for program eligibility. If you still have questions or concerns, please contact or go to the GE website –


On June 26, 2015, ED posted a federal register notice outlining the verification items and required documentation for 2016-2017. Please note that there were not any major changes. There may, however, be a couple of processing changes which will be explained in an upcoming DCL. Stay tuned.

As far as verification items and documentation, there were just a few minor changes to identity theft and amended tax returns. The federal register points out that for identity theft a student must now provide a TRDBV transcript and a signed and dated statement outlining that they were a victim of IRS identity theft. In addition, if a TRDBV is not available, the tax filer can provide a different IRS document or transcript, as long as it contains all of the required data in order to complete verification.

For tax filers that filed an amended return they must now provide the following 3 items: a copy of the original, signed tax return; a copy of an IRS transcript that lists all account information; and a signed 1040X.

In addition, the federal register indicates that, where applicable, a school can accept tax transcripts (or equivalent documents) from foreign countries, U.S. territories, or U.S. commonwealths to complete verification.

Perkins Loans

Please note that ED has posted a series of Q & As dealing with the upcoming wind-down of the Perkins Loan program in the upper right-hand corner of IFAP under “Hot Topics.” If you participate in the Perkins Loan program, please remember to periodically check the Q & As for any updates or new information.

Since I have been getting a lot of questions around the eligibility of grandfathered students who have undeclared majors, I did want to provide the following Q & A –

AWD-Q2: Are students who received their first Perkins Loan when they were enrolled in an “undeclared”, “undecided” or general education major eligible for the grandfather provision when they enroll in a major/program that has a different CIP code?

AWD-A2: Yes, an otherwise eligible Perkins Loan recipient who was enrolled in an undeclared, undecided or general education major in a Title IV eligible program would be eligible to receive a Perkins Loan in subsequent years as a “grandfathered student” when the student has a specific declared major. Of course, once the student is enrolled in a specific academic program, that program becomes the one the student must continue to be enrolled in to receive subsequent Perkins Loans as a grandfathered student.

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