(GENERAL-24-151) Applying for Title IV Approval of an Eligible Career Pathway Program for Ability to Benefit

This Electronic Announcement provides a reminder and brief process for institutions applying for approval of eligible career pathway program(s) (ECPP)(s) for use with Ability to Benefit (ATB) at Title IV-eligible institutions. This guidance compliments the guidance in Dear Colleague Letter (DCL) GEN-24-08.

The Higher Education Act of 1965, as amended (HEA) allows a student who does not have a high school diploma or the recognized equivalent of a high school diploma, or who did not complete a secondary school education in a homeschool setting, to be eligible for Title IV aid through one of the ATB alternatives if the student is enrolled in an “eligible career pathway program,” or ECPP.

Students who are enrolled in an ECPP may be eligible to receive Title IV aid if the student meets one of the following ATB alternatives:

Regulations at 34 CFR 668.157 effective on July 1, 2024, provide new requirements for ECPPs that are used for establishing student eligibility for Title IV funds. For Title IV purposes, ECPP only refers to programs that are approved by the Department to be used to establish student eligibility for Title IV funds through the ATB alternatives listed above. The term Career Pathway Program (CPP) in the context of ATB refers to programs that have been developed for purposes of establishing student eligibility under the ATB alternatives but have not yet been approved by the Department.

As instructed in DCL GEN-24-08, institutions relying on the ATB ECPP alternatives to establish student eligibility for Title IV funds must be able to document that each ATB ECPP offered by the institution meets the eligibility requirements detailed in the cited regulation. That documentation must be provided to the Department when obtaining initial approval for the ATB CPP or when requested by the Department.

Institutions that offered one or more ATB CPPs prior to July 1, 2024, must apply to the Department to have one of its CPPs certified as eligible for Title IV purposes by the earlier of:

Institutions that have not offered an ATB CPP prior to July 1, 2024, must submit an E-App with supporting documentation and receive approval from the Department prior to awarding Title IV aid to prospective students.

To apply for Title IV approval of ECPP(s) for use with Ability to Benefit (ATB), the institution must answer two questions under #8 – Ability to Benefit on the E-App:

For question one, a school should answer “yes” if it plans to use an ATB test, the 6 credit/225 clock hour option, or if it is included in an active approved state process for Ability to Benefit. When “yes” is selected, the institution will be given the opportunity to identify which ATB option(s) it will use for its ECPP(s).

For question two, a school should answer “yes” if it wishes to receive approval of its ECPP(s) for ATB use, and must include the required documentation outlined in Section B of DCL GEN-24-08 with the E-App. If a school has career pathway programs but does not plan to make students eligible for aid to enroll in those programs using ATB, it should answer “no” to question two and is not required to upload program information.

If a school answers yes to one or both questions, and/or uploads any of the required documents, eligibility staff from the School Participation Division (SPD) have specific internal procedures that are followed in reviewing the application and will work with the school to ensure that we have everything needed for approval consideration.

For questions concerning the approval process for eligible career pathway programs, contact your School Participation Division using the contact information on Federal Student Aid’s Partner Connect website.