Title IV Eligibility for Students Without a Valid High School Diploma

The US Department of Education has released a Dear Colleague letter that clarifies changes made by the Consolidated and Further Continuing Appropriations Act of 2015 to the Title IV eligibility of students who are not high school graduates.

Dear Colleague:

The Consolidated and Further Continuing Appropriations Act of 2015 (Pub. L. 113-235) was enacted on December 16, 2014. The new law changed section 484(d) of the Higher Education Act of 1965, as amended (HEA), to allow a student who does not have a high school diploma (or its recognized equivalent), or who did not complete a secondary school education in a homeschool setting, to be eligible for Title IV, HEA student assistance (Title IV aid) through ability to benefit (ATB) alternatives, but only if the student is enrolled in an “eligible career pathway program” as defined in section 484(d)(2) of the HEA and discussed more fully below.

This letter describes the changes made to section 484(d) of the HEA by Pub. L. 113-235, including the reinstatement of ATB alternatives for student eligibility and the statutory definition of an eligible career pathway program for purposes of Title IV aid eligibility. The letter identifies the ATB tests that are currently approved by the Secretary of Education. It also provides information regarding the retroactive implementation of the provisions described above.

Finally, the letter discusses an additional change made to section 401(b)(2)(A)(ii) of the HEA by Pub. L. 113-235. That change provides that students who first enroll in any Title IV eligible postsecondary program on or after July 1, 2015, and who gain eligibility under one of the ATB alternatives, will have their Federal Pell Grant award determined under an alternative Pell Grant disbursement schedule. That provision is described below, and the 2015-2016 Career Pathway Alternative Pell Grant Disbursement Schedules are attached to this letter.