U.S. Department of Education Announces Rules for Historic Pell Grant Experiment

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U.S. Department of Education Announces Rules for Historic Pell Grant Experiment

JFF Weighs in on the Requirements for Participating in the Dual Enrollment Experimental Site Initiative for Federal Pell Grants

Program Requirements    Institutional Eligibility    Notable Rules    Other Considerations    How to Apply

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On October 30, 2015, the U.S. Department of Education announced the launch of an experiment that will expand access to college coursework for high school students from low-income backgrounds. Specifically, for selected postsecondary institutions, the Department will waive financial aid restrictions that prohibit students from accessing Federal Pell Grants. For the first time ever, low-income high school students will have access to Pell Grants to pay for college courses. Jobs for the Future and other partners have worked for several years to make this idea a reality, and we are hopeful and excited that it can support the expansion of strategies like those you are advancing locally.

In its announcement, the Department cited research that suggests that participation in dual enrollment can lead to improved academic outcomes, especially for low-income and first-generation college-going students. However, cost can be a barrier as high school students at many institutions are expected to pay out of pocket for college course tuition, fees, and books. Through an investment of $20 million, the Department hopes to break down these barriers for up to 10,000 low-income students and gain useful data on the impact of federal financial aid on low-income students’ participation and academic success in dual enrollment.

Colleges that want to create or expand partnerships with local education agencies to adopt an early college or grades 9-14+ pathways design (that structure education, training, and career advancement in a seamless continuum) may be well-positioned for this opportunity. The experiment’s requirements appear to be well-aligned with the design features that JFF and other partners have promoted in our support of these strategies nationally.  

We encourage you to consider whether participation in the experiment might help you to advance your goals, and we are providing the following summary of the experiment to assist you as you consider the opportunity. If you decide to apply, please let us know, as we are interested in understanding the degree to which our partners in the field want to participate in experiment.

This memo describes the features, eligibility requirements, and instructions for applying to participate in the experiment. It is intended to highlight and interpret specific items of relevance for our partners, not to be comprehensive or an official source about program requirements. If you intend to apply, we encourage you to read the full Federal Register Notice.


Based on our read of the program requirements, it appears that the Department will be seeking participants that can demonstrate the extent to which their dual enrollment arrangements emphasize the following practices consistent with early college and grade 9-14+ pathways:

1. Promote credit-bearing coursework. 

a. Provide that students will receive Pell Grant funds only for courses that apply toward the completion of a postsecondary credential. 
b. Ensure that Pell Grant funds are not used for remedial coursework. 
c. Ensure that high school students who are dual enrolling are adequately prepared for postsecondary coursework. 

2. Accelerate college completion. 

a. Offer students the opportunity to earn the equivalent of at least 12 postsecondary credit hours (in many cases, the equivalent of one full term) while they are enrolled in high school. 

3. Provide student support services. 

a. This includes assistance with completing the Free Application for Federal Student Aid (FAFSA). Note: This is likely to be a requirement for determining the eligibility of students for federal aid. 
b. Other student support services cited include academic tutoring, high school to college transition support, guidance counseling, or other comparable services designed to increase student preparation for and success in postsecondary education.

4. Cover all costs for students in the experiment. 

a. Participating institutions must exhaust all Pell Grants, state, local, and institutional aid resources and ensure that students are not responsible for any charges. 


Eligible applicants are postsecondary institutions that participate in the student financial assistance programs authorized under title IV of the Higher Education Act of 1965. Participating institutions are expected to be in compliance in their administration of these programs. In addition, student outcomes data such as completion rates, repayment rates, cohort default rates and financial responsibility will also be considered in the selection process. 


Institutions participating in the experiment may not disregard any dual enrollment participation requirements that it already has in place. The experiment will waive only those policies having to do with the awarding of Federal Pell Grants to secondary students. Any other existing rules required by the institution, high schools, LEAs, or SEAs are expected to remain in place. 

Furthermore, funds may not be used to replace existing resources currently being used to support dual enrollment arrangements. According to the Notice, “Federal Pell Grants made available to students to enroll in participating institutions through this experiment must not supplant public and institutional sources of funding for an institution’s dual enrollment arrangement(s).” This suggests that applicants will need to show how receipt of the waiver will create or expand access for low-income students who otherwise would not have had it under existing funding.

Finally, student progress in high school may not be interrupted by participation in the dual enrollment arrangement. Participating institutions should ensure that dual enrollment arrangements do not impede participating students' academic progress and persistence in secondary school. 


Credit transferability. The notice indicates that if there are any restrictions on the transferability of credits in the dual enrollment arrangement, the participating institutions must disclose this to high school students and their families. To the degree your schools and pathways are designed to maximize transferability of courses, it may be worth emphasizing this point, even though it is not a requirement for the experiment.   

STEM and career pathways. For this experiment, the Department is particularly interested in dual enrollment arrangements that are aligned with postsecondary degrees and credentials in high-demand fields, including science, technology, engineering, mathematics (STEM), and computer science, and those aligned with career pathways and other career preparation programs. 

Evaluation and reporting. The Federal Register Notice indicates that participating institutions will be required to “collect, maintain, and report information about students receiving Federal Pell Grants under the experiment”. The Notice provides some examples as to the types of data that participants will be required to collect, but the process and frequency for data reporting and evaluation is yet to be determined. 


Participation in the experiment is likely to be competitive given that the Department has specified an investment level and projected number of students to be impacted. Interested parties must apply for consideration. Potential participants for this experiment are postsecondary institutions that have an arrangement with one or more local education agencies or public high schools. To apply, the postsecondary institution must submit a letter of interest wherein it describes the extent to which it meets the requirements outlined in the Federal Register Notice. In addition, applicants must include an estimate of the number of students who will be served under each proposed dual enrollment arrangement.

Eligible institutions must submit a letter of interest to the Department of Education no later than February 1, 2016 to ensure it is considered for participation in the experiment, though applications received after that day may be considered upon the discretion of the Secretary of Education. Please review the Federal Register Notice for instructions on how and to whom to submit letters of interest. 


On Wednesday, January 13, 2016 1:30-3:00pm EST, the office of Federal Student Aid will host a webinar for postsecondary institutions interested in learning more about the goals, requirements, and process for participating in this experiment. Register for this webinar.

To be considered for participation in the experiment, postsecondary institutions must submit a letter of interest to the Department of Education, following the procedures outlined in the Federal Register Notice, no later than Monday, February 1, 2016 for priority consideration. We invite many postsecondary institutions to apply to expand access and provide support for students.