Hello NCL colleagues, I have a question about the ATB guidance that was issued from DOE last May, 2015. As you may recall, this guidance was intended to offer clarity regarding the reinstated financial aid awards for adults enrolling in post-secondary classes without a high school diploma. The colleges are required to have an Adult Education component that meets the WIOA Title II definition of adult education services. But is it also your understanding that the colleges are allowed to create their own programs or use non-Title II funded entities (WIOA Title I, campus-based TRIO, etc.) to offer the services? If that's the case, then it raises several concerns. First, that non-Title II funded programs could be designated as the Adult Ed component for ATB purposes. These programs may not be accountable for meeting and reporting Title II outcomes while duplicating services of Title II, and their students could receive about $4,800 financial aid for their college level work. Second, it raises the question of the quality and success of these other 'adult education' like programs as compared to our own career pathways programs. I'd appreciate your insights and any more recent information you have regarding the implementation of these guidelines in practice. Thanks, Jackie Taylor

Jackie, I have wondered the same thing.... I don't think that ATB came back for this special population by accident. I believe it was tied very closely to WIOA. I wonder if you want to connect with Jim Hermes from AACC? I think he would have an understanding of the law and the spirit of the law. I look forward to hearing others' perspective too. Thanks for bringing it up, Regina On Tue, Dec 1, 2015 at 11:33 AM, Jackie Taylor <jackie@jataylor.net> wrote: > Hello NCL colleagues, > > I have a question about the ATB guidance that was issued from DOE last May, > 2015. As you may recall, this guidance was intended to offer clarity > regarding the reinstated financial aid awards for adults enrolling in > post-secondary classes without a high school diploma. > > The colleges are required to have an Adult Education component that meets > the WIOA Title II definition of adult education services. But is it also > your understanding that the colleges are allowed to create their own > programs or use non-Title II funded entities (WIOA Title I, campus-based > TRIO, etc.) to offer the services? > > If that's the case, then it raises several concerns. First, that non-Title > II funded programs could be designated as the Adult Ed component for ATB > purposes. These programs may not be accountable for meeting and reporting > Title II outcomes while duplicating services of Title II, and their > students > could receive about $4,800 financial aid for their college level work. > Second, it raises the question of the quality and success of these other > 'adult education' like programs as compared to our own career pathways > programs. > > I'd appreciate your insights and any more recent information you have > regarding the implementation of these guidelines in practice. > > Thanks, > > Jackie Taylor > > > > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: > http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org > -- *Regina Suitt* Dean of Adult Basic Education for College & Career Pima Community College 401 N. Bonita Tucson, Arizona 85709-5600 520-206-6500 *rsuitt@pima.edu <rsuitt@pima.edu>* *Engage Educate Empower* *https://pccadulted.wordpress.com/ <https://pccadulted.wordpress.com/>*

Thanks Regina (and KayLynn) for getting back with me. Regina, if you would please send me Jim’s email address offline I will reach out to him. Call me crazy but I doubt that duplication of services was intended. Jackie From: Suitt, Regina [mailto:rsuitt@pima.edu] Sent: Tuesday, December 1, 2015 2:15 PM To: Jackie Taylor Cc: National Coalition for Literacy Members List Subject: Re: [NCL Members] Concern about the ATB guidance Jackie, I have wondered the same thing.... I don't think that ATB came back for this special population by accident. I believe it was tied very closely to WIOA. I wonder if you want to connect with Jim Hermes from AACC? I think he would have an understanding of the law and the spirit of the law. I look forward to hearing others' perspective too. Thanks for bringing it up, Regina On Tue, Dec 1, 2015 at 11:33 AM, Jackie Taylor <jackie@jataylor.net> wrote: Hello NCL colleagues, I have a question about the ATB guidance that was issued from DOE last May, 2015. As you may recall, this guidance was intended to offer clarity regarding the reinstated financial aid awards for adults enrolling in post-secondary classes without a high school diploma. The colleges are required to have an Adult Education component that meets the WIOA Title II definition of adult education services. But is it also your understanding that the colleges are allowed to create their own programs or use non-Title II funded entities (WIOA Title I, campus-based TRIO, etc.) to offer the services? If that's the case, then it raises several concerns. First, that non-Title II funded programs could be designated as the Adult Ed component for ATB purposes. These programs may not be accountable for meeting and reporting Title II outcomes while duplicating services of Title II, and their students could receive about $4,800 financial aid for their college level work. Second, it raises the question of the quality and success of these other 'adult education' like programs as compared to our own career pathways programs. I'd appreciate your insights and any more recent information you have regarding the implementation of these guidelines in practice. Thanks, Jackie Taylor _______________________________________________ National Coalition for Literacy Members mailing list Members@lists.national-coalition-literacy.org To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org -- Regina Suitt Dean of Adult Basic Education for College & Career Pima Community College 401 N. Bonita Tucson, Arizona 85709-5600 520-206-6500 <mailto:rsuitt@pima.edu> rsuitt@pima.edu Engage Educate Empower https://pccadulted.wordpress.com/

CLASP and JFF did an ATB webinar a couple of weeks back and someone from ED was asked if programs had to be funded by WIOA Title II to quality as adult education. He said the funding was not the issue but the adult education programs had to follow all the "requirements of WIOA Title II." I would interpret that to mean being part of the state adult education system. What do you all think? On Tue, Dec 1, 2015 at 1:15 PM, Suitt, Regina <rsuitt@pima.edu> wrote: > Jackie, > I have wondered the same thing.... I don't think that ATB came back for > this special population by accident. I believe it was tied very closely to > WIOA. I wonder if you want to connect with Jim Hermes from AACC? I think > he would have an understanding of the law and the spirit of the law. > I look forward to hearing others' perspective too. > Thanks for bringing it up, > Regina > > On Tue, Dec 1, 2015 at 11:33 AM, Jackie Taylor <jackie@jataylor.net> > wrote: > >> Hello NCL colleagues, >> >> I have a question about the ATB guidance that was issued from DOE last >> May, >> 2015. As you may recall, this guidance was intended to offer clarity >> regarding the reinstated financial aid awards for adults enrolling in >> post-secondary classes without a high school diploma. >> >> The colleges are required to have an Adult Education component that meets >> the WIOA Title II definition of adult education services. But is it also >> your understanding that the colleges are allowed to create their own >> programs or use non-Title II funded entities (WIOA Title I, campus-based >> TRIO, etc.) to offer the services? >> >> If that's the case, then it raises several concerns. First, that non-Title >> II funded programs could be designated as the Adult Ed component for ATB >> purposes. These programs may not be accountable for meeting and reporting >> Title II outcomes while duplicating services of Title II, and their >> students >> could receive about $4,800 financial aid for their college level work. >> Second, it raises the question of the quality and success of these other >> 'adult education' like programs as compared to our own career pathways >> programs. >> >> I'd appreciate your insights and any more recent information you have >> regarding the implementation of these guidelines in practice. >> >> Thanks, >> >> Jackie Taylor >> >> >> >> >> _______________________________________________ >> National Coalition for Literacy Members mailing list >> Members@lists.national-coalition-literacy.org >> To unsubscribe: >> http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org >> > > > > -- > > *Regina Suitt* > > Dean of Adult Basic Education for College & Career > > Pima Community College > > 401 N. Bonita > > Tucson, Arizona 85709-5600 > > 520-206-6500 > > *rsuitt@pima.edu <rsuitt@pima.edu>* > > > > *Engage Educate Empower* > > > *https://pccadulted.wordpress.com/ <https://pccadulted.wordpress.com/>* > > > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: > http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org >

Currently, there are community colleges offering adult literacy/high school equivalency programs that are not funded under WIOA. Therefore, I interpret the language of meeting the requirements of WIOA to include outcomes, data, etc but not necessarily funding. Is this "duplication"? Only if they are started anew in an area where Title II programs already exist. JoAnn JoAnn Weinberger Co-Chair, Public Policy Committee PAACE > On Dec 1, 2015, at 2:59 PM, Jackie Taylor <jackie@jataylor.net> wrote: > > Thanks Regina (and KayLynn) for getting back with me. > > Regina, if you would please send me Jim’s email address offline I will reach out to him. > > Call me crazy but I doubt that duplication of services was intended. > > Jackie > > From: Suitt, Regina [mailto:rsuitt@pima.edu] > Sent: Tuesday, December 1, 2015 2:15 PM > To: Jackie Taylor > Cc: National Coalition for Literacy Members List > Subject: Re: [NCL Members] Concern about the ATB guidance > > Jackie, > I have wondered the same thing.... I don't think that ATB came back for this special population by accident. I believe it was tied very closely to WIOA. I wonder if you want to connect with Jim Hermes from AACC? I think he would have an understanding of the law and the spirit of the law. > I look forward to hearing others' perspective too. > Thanks for bringing it up, > Regina > > On Tue, Dec 1, 2015 at 11:33 AM, Jackie Taylor <jackie@jataylor.net> wrote: > Hello NCL colleagues, > > I have a question about the ATB guidance that was issued from DOE last May, > 2015. As you may recall, this guidance was intended to offer clarity > regarding the reinstated financial aid awards for adults enrolling in > post-secondary classes without a high school diploma. > > The colleges are required to have an Adult Education component that meets > the WIOA Title II definition of adult education services. But is it also > your understanding that the colleges are allowed to create their own > programs or use non-Title II funded entities (WIOA Title I, campus-based > TRIO, etc.) to offer the services? > > If that's the case, then it raises several concerns. First, that non-Title > II funded programs could be designated as the Adult Ed component for ATB > purposes. These programs may not be accountable for meeting and reporting > Title II outcomes while duplicating services of Title II, and their students > could receive about $4,800 financial aid for their college level work. > Second, it raises the question of the quality and success of these other > 'adult education' like programs as compared to our own career pathways > programs. > > I'd appreciate your insights and any more recent information you have > regarding the implementation of these guidelines in practice. > > Thanks, > > Jackie Taylor > > > > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org > > > > -- > Regina Suitt > Dean of Adult Basic Education for College & Career > Pima Community College > 401 N. Bonita > Tucson, Arizona 85709-5600 > 520-206-6500 > rsuitt@pima.edu > > Engage Educate Empower > https://pccadulted.wordpress.com/ > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org

Jackie, I'd suggest you ask for clarification, from an OCTAE point of view, from Cheryl Keenan. NCAL (Jim and I) have a couple of quick thoughts about the matter, as follows, depending on how we interpret your question. -- There is plenty of intentional overlap between Adult Ed Title I and Title II but there's no reason we know of to conclude that activity that might take place with Title I funding would have anything to do with state grant funding, which is mostly what Title II is still about. -- There are many non-Title II programs that might meet the WIOA definition of Adult Ed. We assume these would be eligible too. Given the promotion of programs like re-entry, SNAP, etc. by OCTAE…and lack of adequate funding for Title II Adult Ed, this is very likely intentional. Otherwise, it would have said/specified thatw only WIOA Title II programs would be eligible. Gail On Dec 1, 2015, at 1:33 PM, Jackie Taylor <jackie@jataylor.net> wrote: > Hello NCL colleagues, > > I have a question about the ATB guidance that was issued from DOE last May, > 2015. As you may recall, this guidance was intended to offer clarity > regarding the reinstated financial aid awards for adults enrolling in > post-secondary classes without a high school diploma. > > The colleges are required to have an Adult Education component that meets > the WIOA Title II definition of adult education services. But is it also > your understanding that the colleges are allowed to create their own > programs or use non-Title II funded entities (WIOA Title I, campus-based > TRIO, etc.) to offer the services? > > If that's the case, then it raises several concerns. First, that non-Title > II funded programs could be designated as the Adult Ed component for ATB > purposes. These programs may not be accountable for meeting and reporting > Title II outcomes while duplicating services of Title II, and their students > could receive about $4,800 financial aid for their college level work. > Second, it raises the question of the quality and success of these other > 'adult education' like programs as compared to our own career pathways > programs. > > I'd appreciate your insights and any more recent information you have > regarding the implementation of these guidelines in practice. > > Thanks, > > Jackie Taylor > > > > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org Gail Spangenberg Founder & Managing Director Adult Learning Partners, LLC 440 East 23rd Street - Ste. 11c New York, NY 10010

  Are articulated and contextualized; and
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  Allow students to advance to higher levels of education and
  employment;
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I don't know if there is guidance more current, but here is what we have. Webinar and Call for Questions on Ability to Benefit *Date and Time*: Monday, Nov. 9, 2015 from 3 to 4:30 p.m. EST Access to financial aid plays a huge role in the ability of students to access, persist in, and complete postsecondary education, especially for those without a high school diploma or its equivalent. In December 2014, Congress partially restored the Ability to Benefit <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&100&&&http://ifap.ed.gov/dpcletters/GEN1509.html> (ATB) provision of the *Higher Education Act*. Under this provision, students who do not have a high school diploma or its recognized equivalent, but who are enrolled in eligible career pathway <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&101&&&http://ifap.ed.gov/dpcletters/GEN1509.html>s programs, may qualify for federal financial aid. In addition to participating in an eligible career pathways program, students wanting to qualify for aid need to pass anapproved test <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&102&&&http://ifap.ed.gov/eannouncements/062415ATBTests.html> or successfully complete six hours of college credit. The partial ATBrestoration provides a great opportunity for thousands of students who will now be able to pursue postsecondary education and training in community and technical colleges, or four-year colleges, and attain the credentials needed for careers in high-demand occupations. To benefit from the restoration, however, students in eligible career pathways programs need help to gain access to resources and information. The webinar will address the following questions: - *What is Ability to Benefit?* - *Who is eligible for Ability to Benefit?* - *What are the two primary ways to help students qualify for ATB and access financial aid for college pathways programs?* - *What constitutes an “eligible” career pathways program?* - *Where can one find the list of ABT tests that qualify students for ATB?* During the Nov. 9 webinar, staff from the U.S. Department of Education will provide guidance on how students can qualify. In addition, state and community college officials will share examples of how Ability to Benefit is being utilized to support low-income, underprepared students. ED is asking webinar participants to submit by Nov. 1 any inquiries on which they would like ED’s guidance. To submit a question(s) please fill out this short survey <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&103&&&https://www.surveymonkey.com/r/AbilityToBenefit>. ED will review the inquiries in advance and respond to as many of them as possible during the webinar. For more resources from Jobs for the Future about how to help underprepared students access and succeed in college, please visit http://www.jff.org/publications/earning-postsecondary-credentials <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&104&&&http://www.jff.org/publications/earning-postsecondary-credentials> . For more background on Ability to Benefit, visit http://www.jff.org/initiatives/accelerating-opportunity/policy-update <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&105&&&http://www.jff.org/initiatives/accelerating-opportunity/policy-update> . Presenters: - Mark Mitsui, deputy assistant secretary for Community Colleges, Office of Career, Technical, and Adult Education; - Carney McCullough, director, Policy Development Group, Office of Postsecondary Education; - David Musser, policy liaison, Federal Student Aid; - Maria Flynn, senior vice president, Jobs for the Future; - Jon Kerr, director of Adult Basic Education, Washington State Board for Community & Technical Colleges; and - Derek Ball, financial aid officer at the Kentucky Community & Technical College System. Facilitators: - Mary Clagett, program director, Jobs for the Future - Lauren E. Walizer, senior policy analyst, Center for Postsecondary and Economic Success, CLASP Please be sure to register for the webinar by clicking here <http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&106&&&http://www.cvent.com/c/express/f199ab6c-aa2e-4879-a781-dd9a09eaa551#/f199ab6c-aa2e-4879-a781-dd9a09eaa551>. Login information for the event will be sent out to registered attendees prior to the event. If you have any questions, contact Lexie Waugh at awaugh@jff.org.. What is a career pathway? http://ifap.ed.gov/dpcletters/GEN1509.html *El**gible Career Pathway Programs* Career pathways refer to a combination of rigorous and high-quality education, training, and support services that are aligned with the skill needs of industries in State or regional economies, preparing individuals to be successful in secondary or postsecondary education programs and the labor market. In recent years, the Federal government has worked to identify the elements of a high-quality career pathway program. Under Pub. L. 113-235, Congress provided an opportunity for students who are enrolled in eligible career pathway programs, but who lack a high school diploma or its recognized equivalent, or who did not complete a secondary school education in a homeschool setting, to become eligible for Title IV aid using one of the ATB alternatives. To become eligible for Title IV aid under one of the ATB alternatives described above, the student must be enrolled in an “eligible career pathway program,” as defined in section 484(d)(2) of the HEA. Any institution, whether public, nonprofit, or for-profit, may offer an eligible career pathway program. An eligible career pathway program must: - Concurrently enroll students in connected adult education and eligible postsecondary programs; - Provide students with counseling and supportive services to identify and attain academic and career goals; - Provide structured course sequences that— - Are articulated and contextualized; and - Allow students to advance to higher levels of education and employment; - Provide opportunities for acceleration for students to attain recognized postsecondary credentials, including degrees, industry relevant certifications, and certificates of completion of apprenticeship programs; - Be organized to meet the needs of adults; - Be aligned with the education and skill needs of the regional economy; and - Have been developed and implemented in collaboration with partners in business, workforce development, and economic development. As stated above, an eligible career pathway program contains two components: an adult education component and a Title IV eligible postsecondary program component. In this context, “adult education” has the same definition as it does under the Adult Education and Family Literacy Act, Title II of the Workforce Innovation and Opportunity Act (Pub. L. 113-128) and includes academic instruction and education services below the postsecondary level that increase an individual’s ability to: - Read, write, and speak in English and perform mathematics or other activities necessary for the attainment of a secondary school diploma or its recognized equivalent; - Transition to postsecondary education and training; and - Obtain employment. The Title IV eligible postsecondary program component of an eligible career pathway program must meet the definition of an eligible program under 34 CFR 668.8 in order for students enrolled in the eligible career pathway program to be eligible for Title IV aid. An eligible career pathway program, as defined in section 484(d)(2) of the HEA, is not itself an eligible program under 34 CFR 668.8 because it contains an adult education component that includes, by definition, coursework that is below the postsecondary level. Therefore, an institution may not include the cost of the adult education component of an eligible career pathway program in a student’s cost of attendance as defined in section 472 of HEA and may not pay for the cost of the adult education component using Title IV aid. The only costs that can be included in a student’s cost of attendance are those associated with the Title IV eligible postsecondary program component. Similarly, credit or clock hours associated with adult education coursework cannot be incorporated into a student’s Title IV enrollment status, regardless of whether the institution considers the adult education coursework to be remedial. However, costs for noncredit or reduced credit remedial coursework that is *not* part of the adult education component of the eligible career pathway program, but is associated with the Title IV eligible postsecondary program component, can be included in a student’s cost of attendance. That coursework can also be included in the student’s Title IV enrollment status. For more information on remedial coursework, please see Volume 1, Chapter 1 of the FSA Handbook. Under the statute, a student is not eligible for Title IV aid if the student is enrolled in elementary or secondary school. However, while the adult education component of an eligible career pathway program includes instruction below the postsecondary level, adult education is not secondary school education. Therefore, a student enrolled in an eligible career pathway program does not lose eligibility because the student is not considered to be enrolled in secondary school. As noted above, the term “career pathway program” is also defined in the Workforce Innovation and Opportunity Act, and in other laws, including State and local laws. The definition of an eligible career pathway program under section 484(d)(2) of the HEA may differ from definitions in these other laws. A program that qualifies for funding under the Workforce Innovation and Opportunity Act or another law may not meet the definition of an eligible career pathway program in section 484(d)(2) of the HEA. To provide Title IV aid to students who are eligible only through one of the ATB alternatives allowed under the new law, an institution must ensure that its eligible career pathway program(s) meets the requirements under section 484(d)(2) of the HEA as described above. On Tue, Dec 1, 2015 at 2:23 PM, JoAnn Weinberger <joann.weinberger@gmail.com > wrote: > Currently, there are community colleges offering adult literacy/high > school equivalency programs that are not funded under WIOA. Therefore, I > interpret the language of meeting the requirements of WIOA to include > outcomes, data, etc but not necessarily funding. Is this "duplication"? > Only if they are started anew in an area where Title II programs already > exist. > > JoAnn > > JoAnn Weinberger > Co-Chair, Public Policy Committee > PAACE > > > On Dec 1, 2015, at 2:59 PM, Jackie Taylor <jackie@jataylor.net> wrote: > > Thanks Regina (and KayLynn) for getting back with me. > > > > Regina, if you would please send me Jim’s email address offline I will > reach out to him. > > > > Call me crazy but I doubt that duplication of services was intended. > > > > Jackie > > > > *From:* Suitt, Regina [mailto:rsuitt@pima.edu <rsuitt@pima.edu>] > *Sent:* Tuesday, December 1, 2015 2:15 PM > *To:* Jackie Taylor > *Cc:* National Coalition for Literacy Members List > *Subject:* Re: [NCL Members] Concern about the ATB guidance > > > > Jackie, > > I have wondered the same thing.... I don't think that ATB came back for > this special population by accident. I believe it was tied very closely to > WIOA. I wonder if you want to connect with Jim Hermes from AACC? I think > he would have an understanding of the law and the spirit of the law. > > I look forward to hearing others' perspective too. > > Thanks for bringing it up, > > Regina > > > > On Tue, Dec 1, 2015 at 11:33 AM, Jackie Taylor <jackie@jataylor.net> > wrote: > > Hello NCL colleagues, > > I have a question about the ATB guidance that was issued from DOE last May, > 2015. As you may recall, this guidance was intended to offer clarity > regarding the reinstated financial aid awards for adults enrolling in > post-secondary classes without a high school diploma. > > The colleges are required to have an Adult Education component that meets > the WIOA Title II definition of adult education services. But is it also > your understanding that the colleges are allowed to create their own > programs or use non-Title II funded entities (WIOA Title I, campus-based > TRIO, etc.) to offer the services? > > If that's the case, then it raises several concerns. First, that non-Title > II funded programs could be designated as the Adult Ed component for ATB > purposes. These programs may not be accountable for meeting and reporting > Title II outcomes while duplicating services of Title II, and their > students > could receive about $4,800 financial aid for their college level work. > Second, it raises the question of the quality and success of these other > 'adult education' like programs as compared to our own career pathways > programs. > > I'd appreciate your insights and any more recent information you have > regarding the implementation of these guidelines in practice. > > Thanks, > > Jackie Taylor > > > > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: > http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org > > > > > > -- > > *Regina Suitt* > > Dean of Adult Basic Education for College & Career > > Pima Community College > > 401 N. Bonita > > Tucson, Arizona 85709-5600 > > 520-206-6500 > > *rsuitt@pima.edu <rsuitt@pima.edu>* > > > > *Engage Educate Empower* > > *https://pccadulted.wordpress.com/ <https://pccadulted.wordpress.com/>* > > > > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: > http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org > > -- *Regina Suitt* Dean of Adult Basic Education for College & Career Pima Community College 401 N. Bonita Tucson, Arizona 85709-5600 520-206-6500 *rsuitt@pima.edu <rsuitt@pima.edu>* *Engage Educate Empower* *https://pccadulted.wordpress.com/ <https://pccadulted.wordpress.com/>*

Here’s the video of that webinar: https://www.youtube.com/watch?v=ZMnKE3BX4OI&feature=youtu.be At 18:01 into the video, adult education is discussed. The ED Title IV representative states the adult education program does not need to receive WIOA Title II funding but “does need to meet the requirements in that act.” From: Members [mailto:members-bounces@lists.national-coalition-literacy.org] On Behalf Of Suitt, Regina Sent: Tuesday, December 01, 2015 4:00 PM To: JoAnn Weinberger <joann.weinberger@gmail.com> Cc: National Coalition for Literacy Members List <members@lists.national-coalition-literacy.org> Subject: Re: [NCL Members] Concern about the ATB guidance I don't know if there is guidance more current, but here is what we have. Webinar and Call for Questions on Ability to Benefit Date and Time: Monday, Nov. 9, 2015 from 3 to 4:30 p.m. EST Access to financial aid plays a huge role in the ability of students to access, persist in, and complete postsecondary education, especially for those without a high school diploma or its equivalent. In December 2014, Congress partially restored the Ability to Benefit<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&100&&&http://ifap.ed.gov/dpcletters/GEN1509.html> (ATB) provision of the Higher Education Act. Under this provision, students who do not have a high school diploma or its recognized equivalent, but who are enrolled in eligible career pathway<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&101&&&http://ifap.ed.gov/dpcletters/GEN1509.html>s programs, may qualify for federal financial aid. In addition to participating in an eligible career pathways program, students wanting to qualify for aid need to pass anapproved test<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&102&&&http://ifap.ed.gov/eannouncements/062415ATBTests.html> or successfully complete six hours of college credit. The partial ATBrestoration provides a great opportunity for thousands of students who will now be able to pursue postsecondary education and training in community and technical colleges, or four-year colleges, and attain the credentials needed for careers in high-demand occupations. To benefit from the restoration, however, students in eligible career pathways programs need help to gain access to resources and information. The webinar will address the following questions: · What is Ability to Benefit? · Who is eligible for Ability to Benefit? · What are the two primary ways to help students qualify for ATB and access financial aid for college pathways programs? · What constitutes an “eligible” career pathways program? · Where can one find the list of ABT tests that qualify students for ATB? During the Nov. 9 webinar, staff from the U.S. Department of Education will provide guidance on how students can qualify. In addition, state and community college officials will share examples of how Ability to Benefit is being utilized to support low-income, underprepared students. ED is asking webinar participants to submit by Nov. 1 any inquiries on which they would like ED’s guidance. To submit a question(s) please fill out this short survey<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&103&&&https://www.surveymonkey.com/r/AbilityToBenefit>. ED will review the inquiries in advance and respond to as many of them as possible during the webinar. For more resources from Jobs for the Future about how to help underprepared students access and succeed in college, please visit http://www.jff.org/publications/earning-postsecondary-credentials<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&104&&&http://www.jff.org/publications/earning-postsecondary-credentials>. For more background on Ability to Benefit, visit http://www.jff.org/initiatives/accelerating-opportunity/policy-update<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&105&&&http://www.jff.org/initiatives/accelerating-opportunity/policy-update>. Presenters: · Mark Mitsui, deputy assistant secretary for Community Colleges, Office of Career, Technical, and Adult Education; · Carney McCullough, director, Policy Development Group, Office of Postsecondary Education; · David Musser, policy liaison, Federal Student Aid; · Maria Flynn, senior vice president, Jobs for the Future; · Jon Kerr, director of Adult Basic Education, Washington State Board for Community & Technical Colleges; and · Derek Ball, financial aid officer at the Kentucky Community & Technical College System. Facilitators: · Mary Clagett, program director, Jobs for the Future · Lauren E. Walizer, senior policy analyst, Center for Postsecondary and Economic Success, CLASP Please be sure to register for the webinar by clicking here<http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTUxMDIzLjUwNTkxODYxJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE1MTAyMy41MDU5MTg2MSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3NDgyNzE4JmVtYWlsaWQ9cnN1aXR0QHBpbWEuZWR1JnVzZXJpZD1yc3VpdHRAcGltYS5lZHUmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&106&&&http://www.cvent.com/c/express/f199ab6c-aa2e-4879-a781-dd9a09eaa551#/f199ab6c-aa2e-4879-a781-dd9a09eaa551>. Login information for the event will be sent out to registered attendees prior to the event. If you have any questions, contact Lexie Waugh at awaugh@jff.org<mailto:awaugh@jff.org>.. What is a career pathway? http://ifap.ed.gov/dpcletters/GEN1509.html Elgible Career Pathway Programs Career pathways refer to a combination of rigorous and high-quality education, training, and support services that are aligned with the skill needs of industries in State or regional economies, preparing individuals to be successful in secondary or postsecondary education programs and the labor market. In recent years, the Federal government has worked to identify the elements of a high-quality career pathway program. Under Pub. L. 113-235, Congress provided an opportunity for students who are enrolled in eligible career pathway programs, but who lack a high school diploma or its recognized equivalent, or who did not complete a secondary school education in a homeschool setting, to become eligible for Title IV aid using one of the ATB alternatives. To become eligible for Title IV aid under one of the ATB alternatives described above, the student must be enrolled in an “eligible career pathway program,” as defined in section 484(d)(2) of the HEA. Any institution, whether public, nonprofit, or for-profit, may offer an eligible career pathway program. An eligible career pathway program must: · Concurrently enroll students in connected adult education and eligible postsecondary programs; · Provide students with counseling and supportive services to identify and attain academic and career goals; · Provide structured course sequences that— o Are articulated and contextualized; and o Allow students to advance to higher levels of education and employment; · Provide opportunities for acceleration for students to attain recognized postsecondary credentials, including degrees, industry relevant certifications, and certificates of completion of apprenticeship programs; · Be organized to meet the needs of adults; · Be aligned with the education and skill needs of the regional economy; and · Have been developed and implemented in collaboration with partners in business, workforce development, and economic development. As stated above, an eligible career pathway program contains two components: an adult education component and a Title IV eligible postsecondary program component. In this context, “adult education” has the same definition as it does under the Adult Education and Family Literacy Act, Title II of the Workforce Innovation and Opportunity Act (Pub. L. 113-128) and includes academic instruction and education services below the postsecondary level that increase an individual’s ability to: · Read, write, and speak in English and perform mathematics or other activities necessary for the attainment of a secondary school diploma or its recognized equivalent; · Transition to postsecondary education and training; and · Obtain employment. The Title IV eligible postsecondary program component of an eligible career pathway program must meet the definition of an eligible program under 34 CFR 668.8 in order for students enrolled in the eligible career pathway program to be eligible for Title IV aid. An eligible career pathway program, as defined in section 484(d)(2) of the HEA, is not itself an eligible program under 34 CFR 668.8 because it contains an adult education component that includes, by definition, coursework that is below the postsecondary level. Therefore, an institution may not include the cost of the adult education component of an eligible career pathway program in a student’s cost of attendance as defined in section 472 of HEA and may not pay for the cost of the adult education component using Title IV aid. The only costs that can be included in a student’s cost of attendance are those associated with the Title IV eligible postsecondary program component. Similarly, credit or clock hours associated with adult education coursework cannot be incorporated into a student’s Title IV enrollment status, regardless of whether the institution considers the adult education coursework to be remedial. However, costs for noncredit or reduced credit remedial coursework that is not part of the adult education component of the eligible career pathway program, but is associated with the Title IV eligible postsecondary program component, can be included in a student’s cost of attendance. That coursework can also be included in the student’s Title IV enrollment status. For more information on remedial coursework, please see Volume 1, Chapter 1 of the FSA Handbook. Under the statute, a student is not eligible for Title IV aid if the student is enrolled in elementary or secondary school. However, while the adult education component of an eligible career pathway program includes instruction below the postsecondary level, adult education is not secondary school education. Therefore, a student enrolled in an eligible career pathway program does not lose eligibility because the student is not considered to be enrolled in secondary school. As noted above, the term “career pathway program” is also defined in the Workforce Innovation and Opportunity Act, and in other laws, including State and local laws. The definition of an eligible career pathway program under section 484(d)(2) of the HEA may differ from definitions in these other laws. A program that qualifies for funding under the Workforce Innovation and Opportunity Act or another law may not meet the definition of an eligible career pathway program in section 484(d)(2) of the HEA. To provide Title IV aid to students who are eligible only through one of the ATB alternatives allowed under the new law, an institution must ensure that its eligible career pathway program(s) meets the requirements under section 484(d)(2) of the HEA as described above. On Tue, Dec 1, 2015 at 2:23 PM, JoAnn Weinberger <joann.weinberger@gmail.com<mailto:joann.weinberger@gmail.com>> wrote: Currently, there are community colleges offering adult literacy/high school equivalency programs that are not funded under WIOA. Therefore, I interpret the language of meeting the requirements of WIOA to include outcomes, data, etc but not necessarily funding. Is this "duplication"? Only if they are started anew in an area where Title II programs already exist. JoAnn JoAnn Weinberger Co-Chair, Public Policy Committee PAACE On Dec 1, 2015, at 2:59 PM, Jackie Taylor <jackie@jataylor.net<mailto:jackie@jataylor.net>> wrote: Thanks Regina (and KayLynn) for getting back with me. Regina, if you would please send me Jim’s email address offline I will reach out to him. Call me crazy but I doubt that duplication of services was intended. Jackie From: Suitt, Regina [mailto:rsuitt@pima.edu] Sent: Tuesday, December 1, 2015 2:15 PM To: Jackie Taylor Cc: National Coalition for Literacy Members List Subject: Re: [NCL Members] Concern about the ATB guidance Jackie, I have wondered the same thing.... I don't think that ATB came back for this special population by accident. I believe it was tied very closely to WIOA. I wonder if you want to connect with Jim Hermes from AACC? I think he would have an understanding of the law and the spirit of the law. I look forward to hearing others' perspective too. Thanks for bringing it up, Regina On Tue, Dec 1, 2015 at 11:33 AM, Jackie Taylor <jackie@jataylor.net<mailto:jackie@jataylor.net>> wrote: Hello NCL colleagues, I have a question about the ATB guidance that was issued from DOE last May, 2015. As you may recall, this guidance was intended to offer clarity regarding the reinstated financial aid awards for adults enrolling in post-secondary classes without a high school diploma. The colleges are required to have an Adult Education component that meets the WIOA Title II definition of adult education services. But is it also your understanding that the colleges are allowed to create their own programs or use non-Title II funded entities (WIOA Title I, campus-based TRIO, etc.) to offer the services? If that's the case, then it raises several concerns. First, that non-Title II funded programs could be designated as the Adult Ed component for ATB purposes. These programs may not be accountable for meeting and reporting Title II outcomes while duplicating services of Title II, and their students could receive about $4,800 financial aid for their college level work. Second, it raises the question of the quality and success of these other 'adult education' like programs as compared to our own career pathways programs. I'd appreciate your insights and any more recent information you have regarding the implementation of these guidelines in practice. Thanks, Jackie Taylor _______________________________________________ National Coalition for Literacy Members mailing list Members@lists.national-coalition-literacy.org<mailto:Members@lists.national-coalition-literacy.org> To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org -- Regina Suitt Dean of Adult Basic Education for College & Career Pima Community College 401 N. Bonita Tucson, Arizona 85709-5600 520-206-6500<tel:520-206-6500> rsuitt@pima.edu<mailto:rsuitt@pima.edu> Engage Educate Empower https://pccadulted.wordpress.com/ _______________________________________________ National Coalition for Literacy Members mailing list Members@lists.national-coalition-literacy.org<mailto:Members@lists.national-coalition-literacy.org> To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org -- Regina Suitt Dean of Adult Basic Education for College & Career Pima Community College 401 N. Bonita Tucson, Arizona 85709-5600 520-206-6500 rsuitt@pima.edu<mailto:rsuitt@pima.edu> Engage Educate Empower https://pccadulted.wordpress.com/