The Ability to Benefit (ATB) provision in the Higher Education Act (HEA) allows low-skilled individuals to access necessary workforce training and education that can help lift them out of poverty. It does so by allowing individuals without a high school diploma or equivalent to qualify for federal financial aid for postsecondary education when they participate in an eligible career pathway.

Five months ago, Congress passed the Consolidated Appropriations Act of 2016 which made changes to the amount of Pell Grant for which ATB students are eligible and to the definition of career pathway used in determining eligibility for ATB. To help postsecondary institutions implement these changes, the U.S. Department of Education (ED) released updated guidance last week. Individuals and organizations, like CLASP, concerned with low-skilled students’ access to Title IV aid should be pleased with the results.

First, students who participate in an ATB alternative are now eligible for the full Pell award—$5,815 in the 2016-2017 award year. Formerly, ATB students were eligible for a reduced award, which created an unfair and unprecedented two-tier Pell eligibility standard.

Second, the new ATB eligible career pathway definition mirrors the Workforce Innovation and Opportunity Act (WIOA), aligning the career pathway development and implementation underway for WIOA with access to federal financial aid. The previous standard required students to be “concurrently” enrolled in both adult education and postsecondary programs, and it did not well define what could be characterized as adult education. The new definition provides that the career pathway “enables an individual to attain” a high school diploma or equivalency. This clarifies the intent of ATB to support students without a high school diploma or equivalency in both secondary and postsecondary credential attainment.

Further, in its updated Q&A document, ED clearly states that students are not required to be concurrently enrolled in both an adult education and Title IV student financial aid-eligible program, but must at least “participate in the [adult education] component” before completing the postsecondary credential (emphasis added).

ED also reiterated previous applicable guidance, including that institutions must document how their program meets each of the seven elements of the career pathway definition,  how students who receive aid under ATB are eligible for such aid, and that programs do not need to obtain (and ED will have no process to undertake) formal approvals as a career pathway program. This should inspire institutions to take action, knowing there are not extensive barriers in place that limit starting up such a program.

We encourage postsecondary education officials, particularly financial aid administrators, to take notice of this guidance and consider starting your research on eligible career pathways at CLASP’s ATB resource page. Since the new definition of career pathways aligns with the WIOA definition, there are likely career pathways being developed in your local area to connect with and leverage. WIOA agencies now developing such pathways should also provide information to reassure postsecondary institutions that they meet all seven elements of the “eligible career pathway” definition, which will allow individuals pursuing these pathways to obtain federal financial aid.

Two examples of adult education state initiatives illustrate how local providers are delivering programs that “enable an individual to attain a high school diploma or its recognized equivalent” and encourage innovation and partnership with postsecondary education. Both could be tailored to an ATB eligible career pathway program:

• Wisconsin’s High School Equivalency Diplomas and Certificates legislation offers a menu of alternative high school credentialing processes, including the attainment of at least 24 postsecondary semester credits (Pl 5.07) or the completion of a program approved by the state superintendent (Pl 5.09).
• State of Washington’s 21-Plus competency-based high school equivalency program expands existing secondary completion options with a comprehensive assessment of academic, career, and personal competencies.

With this new definition in the HEA law, it’s clearer than ever that postsecondary institutions have many WIOA partners available to work with them in supporting postsecondary success of adult learners.