# Direct Federal Support of Individuals Pursuing Training and Education in Non-degree Programs > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/crs%3AR46306 ## Record - **Collection:** Congressional research report - **Document type:** CRS Report - **Published:** April 3, 2020 - **Citation:** R46306 ## Text Direct Federal Support of Individuals Pursuing Training and Education in Nondegree Programs Cassandria Dortch Specialist in Education Policy David H. Bradley Specialist in Labor Economics Alexandra Hegji Analyst in Social Policy April 3, 2020 Congressional Research Service 7-.... www.crs.gov R46306 SUMMARY Direct Federal Support of Individuals Pursuing Training and Education in Non-degree Programs Recent Administrations and Congress have demonstrated bipartisan support for increasing federal assistance to individuals pursuing training and education in postsecondary non-degree programs, sometimes referred to as short-term programs. Non-degree programs are postsecondary training and education programs that are most often shorter in duration than a bachelor’s or associate’s degree program. They generally provide work-based learning or educational instruction to individuals who are beyond the typical age for secondary education to prepare them for a particular occupation. Examples of support have included proposals to expand existing federal programs, create new programs, and improve coordination between existing programs. This report provides an overview of existing federal programs and benefits that support individuals pursuing training and education in non-degree programs. R46306 April 3, 2020 Cassandria Dortch Specialist in Education Policy -redacted-@crs.loc.gov David H. Bradley Specialist in Labor Economics -redacted-@crs.loc.gov Alexandra Hegji Analyst in Social Policy -redacted-@crs.loc.gov For a copy of the full report, please call 7-.... or visit www.crs.gov. A prominent argument for supporting individuals pursuing training and education in non-degree programs is that there is a substantial employer need for individuals with some postsecondary credentials but no degree. In 2018, approximately 72% of jobs in the national economy were in occupations for which the typical entry-level education is less than an associate’s degree. Just over 6% explicitly required a non-degree credential, but these credentials could prepare individuals for many jobs that do not require a bachelor’s or higher level degree. Mean annual wages for individuals whose highest educational attainment is high school completion are similar to those for individuals with a non-degree credential. Earnings for individuals with only non-degree credentials vary based on differences in occupational field, program duration, and type of educational institution attended. Several federal programs provide direct financial support to or on behalf of students to enable them to pursue training and postsecondary education in non-degree instructional and work-based learning programs. None of these federal programs or benefits that provide such support focus exclusively on promoting non-degree program pursuits. The federal programs include the following:  Title I of the Workforce Innovation and Opportunity Act (WIOA; P.L. 113-128) is the primary federal workforce development statute. The program relies on state and local workforce development boards to enter into contracts with training and education program providers and oversee the quality of the providers.  Title IV of the Higher Education Act of 1965 (HEA; P.L. 89-329), as amended, authorizes grant and loan programs that provide financial assistance to higher education students. Non-degree program quality assessment is handled by state authorizers, accrediting agencies, and in some instances through Department of Education certification.  Education tax benefits, administered by the Internal Revenue Service (IRS), partially offset some of the costs of higher education for eligible taxpayers. Many education tax benefits are only available to individuals enrolled in a degree program, but three education tax benefits can also be claimed for postsecondary non-degree programs: the Lifetime Learning Credit, the Exclusion for Employer Provided Educational Assistance, and tax-advantaged 529 plan education savings accounts.  The Post-9/11 GI Bill and Veteran Employment Through Technology Education Courses (VET TEC) were originally intended to help veterans enter the civilian workforce. Post-9/11 GI Bill program quality is primarily overseen by state agencies under contract with the Department of Veterans Affairs. VET TEC program quality is assured by withholding 50% of tuition and fees from providers until participants are employed.  Supplemental Nutrition Assistance Program (SNAP) Employment & Training (E&T) provides eligible lowincome households with employment and education services. E&T funding is administered by state agencies through contracted providers, which receive funds to cover education and other program costs. Congressional Research Service Direct Federal Support of Individuals Pursuing Training & Education  The Temporary Assistance for Needy Families (TANF) block grant is best known for providing monthly cash assistance to needy families with children but may be used to support subsidized employment, on-thejob training, and training and education programs. Congressional Research Service Direct Federal Support of Individuals Pursuing Training & Education Contents Introduction ..................................................................................................................................... 1 Labor Market for Non-degree Programs ......................................................................................... 3 Non-degree Programs ...................................................................................................................... 4 Non-degree Instructional Programs .......................................................................................... 5 Non-degree Instructional Program Providers ..................................................................... 6 Duration, Structure, and Cost of Programs ......................................................................... 6 Credit and Noncredit Programs .......................................................................................... 7 Participation Data ............................................................................................................... 8 Work-Based Learning Programs ............................................................................................... 8 Registered Apprenticeship (RA) ......................................................................................... 9 Providers ........................................................................................................................... 10 Structure, Duration, and Cost of Programs ....................................................................... 10 Participation Data ............................................................................................................. 10 Federal Programs and Benefits .......................................................................................................11 WIOA Contracts and Individual Training Accounts (ITAs) (DOL) ........................................ 15 Eligibility of Non-degree Programs .................................................................................. 15 Participant Eligibility for Training .................................................................................... 16 Basic Benefit Payment Structure ...................................................................................... 17 Basic Administrative Structure ......................................................................................... 18 Quality Assurance Mechanisms ........................................................................................ 18 Measures of Program Performance ................................................................................... 18 Program Participation ....................................................................................................... 19 Program Limitations ......................................................................................................... 20 HEA Title IV Federal Student Aid (ED) ................................................................................. 20 Eligibility of Non-degree Programs .................................................................................. 21 Participant Eligibility ........................................................................................................ 23 Basic Benefit Payment Structure ...................................................................................... 24 Basic Administrative Structure ......................................................................................... 25 Quality Assurance Mechanisms ........................................................................................ 25 Measures of Program Performance ................................................................................... 28 Program Participation ....................................................................................................... 28 Program Limitations ......................................................................................................... 29 Tax Benefits (IRS)................................................................................................................... 31 Eligibility of Non-degree Programs .................................................................................. 32 Participant Eligibility for Training .................................................................................... 33 Basic Benefit Payment Structure ...................................................................................... 33 Basic Administration ......................................................................................................... 34 Quality Assurance Mechanisms ........................................................................................ 35 Measures of Program Performance ................................................................................... 35 Program Participation ....................................................................................................... 35 Program Limitations ......................................................................................................... 36 Veterans Education Programs (Post-9/11 GI Bill® and VET TEC) (VA) ............................... 36 Eligibility of Non-degree Programs .................................................................................. 37 Participant Eligibility for Training .................................................................................... 38 Basic Benefit Payment Structure ...................................................................................... 38 Basic Administrative Structure ......................................................................................... 39 Congressional Research Service Direct Federal Support of Individuals Pursuing Training & Education Quality Assurance Mechanisms ........................................................................................ 39 Measures of Program Performance ................................................................................... 40 Program Participation ....................................................................................................... 41 Program Limitations ......................................................................................................... 44 Supplemental Nutrition Assistance Program (SNAP) Employment & Training (E&T) (USDA) ................................................................................................................................ 44 Eligibility of Non-degree Programs .................................................................................. 46 Participant Eligibility for Training .................................................................................... 46 Basic Benefit Payment Structure ...................................................................................... 47 Basic Administrative Structure ......................................................................................... 48 Quality Assurance Mechanisms ........................................................................................ 48 Measures of Program Performance ................................................................................... 48 Program Participation ....................................................................................................... 49 Program Limitations ......................................................................................................... 49 Temporary Assistance for Needy Families (TANF) (HHS) .................................................... 49 Eligibility of Non-degree Programs .................................................................................. 50 Participant Eligibility for Training .................................................................................... 50 Basic Benefit Payment Structure ...................................................................................... 50 Basic Administrative Structure ......................................................................................... 51 Quality Assurance Mechanisms ........................................................................................ 51 Measures of Program Performance ................................................................................... 51 Program Participation and Outcomes ............................................................................... 51 Program Limitations ......................................................................................................... 51 Tables Table 1. Occupational Employment and Wages, by Typical Entry-Level Education Required: May 2018.................................................................................................... 4 Table 2. Examples of Work-Based Learning ................................................................................... 8 Table 3. Selected Characteristics of Federal Programs Supporting Students who Pursue Training or Education Through Non-degree Programs .............................................................. 13 Table 4. Percentage of WIOA Title I Program Exiters, by Training Type ..................................... 20 Table 5. Number and Percentage of Non-degree Instructional Credit Programs and Awards by Institutional Control: AY2017-2018 ......................................................................... 28 Table 6. Examples of Non-degree Programs Approved for GI Bill Purposes ............................... 37 Contacts Author Contact Information .......................................................................................................... 52 Congressional Research Service Direct Federal Support of Individuals Pursuing Training & Education Introduction In recent years, policymakers, industry stakeholders, and educational institutions have shown an interest in the federal government increasing financial support to individuals who pursue training and postsecondary education in non-degree instructional and work-based learning programs. These are instructional or work-based programs designed primarily for individuals beyond high school age and for which a degree is not conferred upon completion. Such programs include, but are not limited to, apprenticeships (e.g., masonry), college certificate programs (e.g., medical billing), and courses that lead to professional certificates or licensure (e.g., Microsoft certifications). By some accounts, there already is, and will continue to be, demand for workers to fill jobs that do not require a college degree but do require training or postsecondary education (e.g., skilled electrical work, health care support services). In addition, there is some evidence that the percentage of jobs requiring more than a high school diploma but not a degree is increasing.1 Although the federal government annually makes available over $100 billion in direct financial aid to individuals pursuing postsecondary education, the overwhelming majority of those funds are not available to a significant proportion of the individuals pursuing training and education through postsecondary non-degree programs. As some traditional colleges experience declining enrollment, some schools have shown an interest in creative approaches to increasing enrollment and maintaining revenues, including reaching out to adults who want to pursue completion of short programs that allow quick reentry into the workforce and/or increase earnings.2 Given the purported demand for workers with certain postsecondary non-degree credentials, Congress may consider viable options for providing direct federal support to students pursuing the completion of non-degree programs. Several proposals have surfaced recently that would increase direct federal support to students pursuing training and education in non-degree (short-term) programs. From 2011 to 2017, the Department of Education (ED) experimented with allowing Pell Grants to be received for shortterm non-degree postsecondary education programs.3 In October 2019, the House Committee on Education and Labor ordered reported the College Affordability Act (H.R. 4674), which would comprehensively reauthorize the Higher Education Act (HEA) and would expand the types of non-degree programs eligible for Pell Grants.4 In 2018, the President’s Council of Economic Advisers presented options for bringing 25- to 64-year-olds back into the workforce with the skills required in the changing economy in an effort to increase the rate of economic growth. These included providing unemployment insurance benefits for individuals while training, providing Pell Grants for some short-term training programs, and developing a new 1 William C. Symonds, Robert Schwartz, and Ronald F. Ferguson, Pathways to prosperity: Meeting the challenge of preparing young Americans for the 21st century (Cambridge, MA: Pathways to Prosperity Project, Harvard University Graduate School of Education, 2011), p. 3, https://www.gse.harvard.edu/sites/default/files/documents/ Pathways_to_Prosperity_Feb2011-1.pdf. 2 Eric Kelderman, “Enrollment Shortfalls Spread to More Colleges,” The Chronicle of Higher Education, May 20, 2019; Jon Marcus, “New Research Questions the Value of Certificates Pushed by Colleges, Policymakers,” The Hechinger Report, October 24, 2017, https://hechingerreport.org/new-research-questions-value-certificates-pushedcolleges-policymakers/; and Clifford Adelman, Ph.D., Searching for Our Lost Associate’s Degrees: Project Win-Win at the Finish Line, Institute for Higher Education Policy, Washington, DC, October 2013, http://www.ihep.org/sites/ default/files/uploads/docs/pubs/pww_at_the_finish_line-long_final_october_2013.pdf. 3 U.S. Department of Education, Experimental Sites Initiative, Experiments, https://experimentalsites.ed.gov/exp/ approved.html on February 18, 2020. 4 For more detail on the provisions, see the “Job Training Pell Grants” section of CRS Report R46176, H.R. 4674, the College Affordability Act: Proposed Reauthorization of the Higher Education Act, Summary of Major Provisions. Congressional Research Service 1 Direct Federal Support of Individuals Pursuing Training & Education comprehensive program for retraining displaced workers.5 The President’s FY2021 budget request for ED proposed expanding Pell Grants to short-term programs that are not currently Pelleligible.6 Several education and business organizations have supported extending Pell Grants, and occasionally Direct Loans, to programs that are shorter in duration than those that are currently eligible.7 Some stakeholders, however, express concerns about promoting non-degree programs and increasing financial support for students pursuing them. There is concern that some non-degree programs do not increase the employment or earnings of completers compared to individuals whose highest level of education is high school completion. Some concerns focus on how the federal government would ensure the quality of the programs.8 Other concerns focus on potentially high federal costs associated with supporting the programs, the potential need for student supports and business coordination, and the possibility of perpetuating income inequalities by fostering lower income students to pursue non-degree programs that lead to lower income professions.9 Some have raised questions about the demonstrated diminishing labor market returns over time for some technical non-degree programs, including apprenticeships.10 Additionally, some non-degree educational programs intended to prepare individuals for a specific occupation are neither required by nor necessarily preferred by employers, although the programs may be of a high quality.11 In light of evidence of employers increasingly relying on degrees when establishing hiring requirements,12 non-degree credential holders may have more difficulties in securing employment over the long term. In addition, adults with degrees currently employed in positions that do not require a degree may be crowding non-degree holders out of some occupations. In 2018, for 5 Executive Office of the President, Council of Economic Advisers, Addressing America’s Reskilling Challenge, July 2018, https://www.whitehouse.gov/wp-content/uploads/2018/07/Addressing-Americas-Reskilling-Challenge.pdf. 6 Office of Management and Budget, A Budget for America’s Future – President’s Budget FY 2021. 7 Andrew Kreighbaum, “Brewing Battle Over Pell Grants,” Inside Higher ED, July 8, 2019; and Opportunity America, the American Enterprise Institute for Public Policy Research, and the Brookings Institution, Work, Skills, Community: Restoring Opportunity for the Working Class, 2018, p. 15, http://www.aei.org/spotlight/work-skills-community-report/ (Hereinafter referred to as “Restoring Opportunity for the Working Class, 2018”). 8 Michelle Van Noy, Heather McKay, and Suzanne Michael, Non-Degree Credential Quality: A Conceptual Framework to Guide Measurement, Rutgers Education and Employment Research Center, July 2019, https://smlr.rutgers.edu/sites/default/files/rutgerseerc_ndcquality_framework_full_paper_final.pdf. 9 Paul Fain, “Support Grows for Major Shift in Pell,” Inside Higher Ed, July 10, 2017, https://www.insidehighered.com/news/2017/07/10/support-builds-expanding-pell-eligibility-short-term-certificates; Restoring Opportunity for the Working Class, 2018, p. 15. 10 Clive Belfield and Thomas Bailey, The Labor Market Returns to Sub-Baccalaureate College: A Review, Center for Analysis of Postsecondary Education and Employment, A CAPSEE Working Paper, March 2017, https://capseecenter.org/labor-market-returns-sub-baccalaureate-college-review/; and Eric A. Hanushek, Ludger Woessmann, and Lei Zhang, General Education, Vocational Education, and Labor-Market Outcomes Over the LifeCycle, National Bureau of Economic Research, Working Paper 17504, Cambridge, MA, October 2011, https://www.nber.org/papers/w17504.pdf (which found that the change in labor market returns with age did not exist in the United States and other countries with a small non-degree education system). 11 Jon Marcus, “New Research Questions the Value of Certificates Pushed by Colleges, Policymakers,” The Hechinger Report, October 24, 2017, https://hechingerreport.org/new-research-questions-value-certificates-pushed-collegespolicymakers/. 12 Opportunity America, the American Enterprise Institute for Public Policy Research, and “Restoring Opportunity for the Working Class, 2018, p. 66. Congressional Research Service 2 Direct Federal Support of Individuals Pursuing Training & Education instance, 28% of employment was in occupations that typically require a degree for entry-level positions, while 42% of the population aged 18 and over had a degree.13 This report provides an overview of existing federal programs and benefits that support individuals engaged in the pursuit of training and education in non-degree instructional and workbased learning programs. It informs consideration of additional or revised policy approaches aiming to support pursuit of training and education through non-degree programs. The report begins with a brief description of employer demand for individuals who have completed nondegree programs. This is followed by a discussion of the landscape and key characteristics of non-degree programs, from those offered through work-based learning to those offered through more formal instructional means. The report concludes with a detailed description of six federal programs and three tax benefits that currently provide direct financial support to students pursuing training and postsecondary education in non-degree instructional and work-based learning programs.14 Each program and benefit description highlights potential gaps and limitations in the scope and extent to which the program or benefit supports individuals pursuing non-degree programs, as well as student eligibility requirements and federal administration and oversight. Labor Market for Non-degree Programs Key stimuli for promoting financial support for individuals pursuing training and postsecondary education in non-degree programs include that the unfulfilled employer/business need for individuals with non-degree credentials is impeding, and/or will impede, economic growth; and that an individual’s attainment of a non-degree postsecondary credential provides a worthwhile payoff. This section of the report provides data on the proportion of total employment and mean wages earned in occupations by typical entry-level education requirements. This discussion provides a sense of the market for non-degree credentials. It does not offer a comprehensive exposition of labor market returns and social impacts of increased non-degree program completion. In May 2018, approximately 6.2% of jobs in the national economy were in occupations for which the typical entry-level education requirement was a non-degree postsecondary credential (Table 1). The Department of Labor’s (DOL’s) Bureau of Labor Statistics (BLS) assigns a typical entrylevel education requirement—the typical education level most workers need to enter an occupation—for occupations that it tracks.15 Table 1 also presents the mean annual wages for occupations by typical entry-level education required. Mean annual wages for occupations that, at entry, require a high school diploma or its equivalent, some college but no degree, or a non-degree credential are all similar. While Table 1 13 Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment Statistics, Overview of May 2018 occupational employment and wages, https://www.bls.gov/oes/current/overview_2018.htm (last modified date: March 29, 2019); and Census Bureau, Table 1. Educational Attainment of the Population 18 Years and Over, by Age, Sex, Race, and Hispanic Origin: 2018, February 21, 2019, https://www.census.gov/data/tables/2018/demo/educationattainment/cps-detailed-tables.html. 14 Noneducation related benefits for families with dependents aged 19 to 23 who are students are not included. Programs that provide income support (e.g., unemployment insurance), subsistence (e.g., Section 8 Project-Based Rental Assistance), or other resources (e.g., Child Care and Development Fund) to eligible individuals, including students, are not included. 15 For a discussion of BLS data limitations regarding the entry-level education requirements, see U.S. Department of Labor, Bureau of Labor Statistics, “Employment Projections: Measures of education and training,” press release, October 24, 2017, https://www.bls.gov/emp/documentation/education/tech.htm. Congressional Research Service 3 Direct Federal Support of Individuals Pursuing Training & Education shows differences in mean annual wages across education categories, these wages do not capture differences within the categories, which in many cases may include sizeable earnings differentials. For example, some research has found earnings premiums for individuals attaining long-term certificates, certificates in technical (e.g., electronics) and health fields, certificates in the field in which the individual works, and certificates from community colleges.16 Table 1. Occupational Employment and Wages, by Typical Entry-Level Education Required: May 2018 Typical Entry-Level Education Requirement for Occupationa Share of Total Employment (%) Mean Annual Wageb Doctoral or professional degree 2.5 $130,090 Master’s degree 1.9 $77,430 Bachelor’s degree 21.7 $87,130 Associate’s degree 2.3 $56,970 Non-degree credential 6.2 $42,530 Some college, no degree 2.5 $39,470 High school diploma or equivalent 38.7 $43,060 No formal educational credential 24.2 $27,890 All occupations 100.0 $51,960 Source: U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, Overview of May 2018 occupational employment and wages, https://www.bls.gov/oes/current/overview_2018.htm (last modified date: March 29, 2019). a. The typical education needed for entry represents the typical education level most workers need to enter an occupation. b. The mean annual wage is calculated by summing the wages of all the employees in a given occupation and then dividing the total wages by the number of employees. Non-degree Programs Postsecondary non-degree programs provide training and education primarily to individuals who are beyond the typical age for secondary education. Most, but not all, non-degree programs are intended to prepare individuals for a particular occupation. Non-degree programs may be described by various classifications. One commonly used classification scheme delineates programs primarily provided by educational institutions (non-degree instructional) and by employers (work-based learning), although some programs include both instructional training and work-based learning. 16 Mark Schneider, Higher Education Pays: Measuring the Economic Security of Florida’s Postsecondary Graduates, College Measures, p. 70; Research for Action, Research Brief: Measuring the Effects of Outcomes-Based Funding on Certificate Production: Challenges, Inconsistencies and Recommendations for Future Research, February 2019, pp. 4-5; and Mina Dadgar and Madeline Joy Trimble, “Labor Market Returns to Sub-Baccalaureate Credentials: How Much Does a Community College Degree or Certificate Pay?,” Educational Evaluation and Policy Analysis, vol. 37, no. 4 (December 2015), p. 399–418, overview at https://ccrc.tc.columbia.edu/publications/labor-market-returns-subbaccalaureate.html. Congressional Research Service 4 Direct Federal Support of Individuals Pursuing Training & Education Non-degree Instructional Programs In general, postsecondary non-degree instructional programs are a combination of postsecondary courses or a postsecondary curriculum that fulfills an educational or professional objective, but for which a student does not earn a degree upon completion. What Characterizes a Postsecondary Non-degree Instructional Program? What Characterizes a Postsecondary Degree Program? For purposes of this report, a postsecondary nondegree instructional program is any curriculum or any combination of courses or subjects that generally fulfills one or more identified educational, professional, avocational, or vocational objectives; does not lead to a degree; is primarily offered through instruction; primarily enrolls individuals beyond the compulsory age of education; and does not require being enrolled in or having completed a bachelor’s or higher degree program. Non-degree instructional programs may be required to meet accreditation standards if offered for credit; meet state board, licensure, or certification standards if required for state board approval, licensure, or certification; or meet state education law standards if offered by an educational institution, as required by state law. This definition is adapted from 38 U.S.C. §3452(b) and U.S. Department of Education, National Center for Education Statistics, Data Point: Degree and Non-degree Credentials Held by Labor Force Participants, NCES 2018-057, March 2018. A degree program at postsecondary educational institutions confers a degree—an associate’s degree, bachelor’s degree, or higher level academic degree (e.g., doctoral degree)—on students who successfully complete the program. The postsecondary educational institution must either be empowered by the appropriate state education authority under state law to offer the degree program, or in some instances be approved by a recognized accrediting agency to offer a degree program (38 U.S.C. §3452(f)). Laws, regulations, and practices pertaining to degree program requirements vary across the states. State requirements may be administered by a state higher education entity, state nursing board, state professional licensing and certification board, state workforce development board, or other entity. States establish degree program requirements that vary, but often are related to credit hours, curriculum, and employment prospects of program completers (See, for example, Pennsylvania Code §31.21, Washington Administrative Code 250-61-100, or 23 Illinois Administrative Code 1030). Non-degree instructional programs prepare individuals for a wide variety of specialized jobs and more general employment. Upon completion of a non-degree instructional program, individuals receive a postsecondary educational certificate, which is a credential awarded by an educational institution based on the completion of a postsecondary instructional program, including coursework, assessment, or other performance evaluations.17 Individuals pursue non-degree programs for various reasons, including to expand knowledge and skills, to prepare for further education, to prepare for employment, to sustain employment, and when seeking promotion. For purposes of this report, non-degree instructional programs exclude those that lead to postbaccalaureate certificates and exclude transfer programs. Typically, transfer programs do not award a certificate or degree, but provide education for at least two academic years and are acceptable for full credit toward a bachelor’s degree. Non-degree instructional programs should not be confused with certifications and licenses, which are occupational credentials awarded by entities that assess whether individuals have met established occupational standards or requirements.18 Licenses are required to practice in some 17 S. Cronen, M. McQuiggan, and E. Isenberg, Adult Training and Education: Results from the National Household Education Surveys Program of 2016 (NCES 2017-103rev), National Center for Education Statistics, Institute of Education Sciences, U.S. Department of Education. Washington, DC, 2017, p. 1, https://nces.ed.gov/pubs2017/ 2017103rev.pdf (Hereinafter referred to as “NCES 2017-103rev”). 18 A certification is an occupational credential awarded by a certification body, such as a professional association or certifying board, based on an individual demonstrating through an examination process that he or she has acquired the Congressional Research Service 5 Direct Federal Support of Individuals Pursuing Training & Education occupations. Certifications show that an individual has attained competency in an occupation. Some certifications and licenses require the completion of a non-degree instructional (or degree) program. Non-degree Instructional Program Providers A diverse set of entities offer non-degree instructional programs. Traditional postsecondary educational institutions—colleges and universities—offer non-degree instructional programs, as do trade, vocational, and technical schools. In fall 2018, almost 3,000 institutions of higher education enrolled nearly1.9 million non-degree seeking undergraduate students.19 Other entities also offer such programs, including businesses; professional organizations; trade unions; nonprofit organizations; federal, state, and local governments; museums; bootcamps; hospitals; and the military. One study estimated that there were over 4,500 for-profit non-traditional postsecondary educational institutions enrolling almost 670,000 students in academic year (AY) 2009-2010.20 Duration, Structure, and Cost of Programs Stackable Units Non-degree instructional programs vary considerably in length and duration. Programs A stackable unit is a sequence of independent programs that are aligned to a career path and that progress to may require a few days or more than two higher-level certificates or credentials. Each stackable years to complete. Generally, the length is credential qualifies an individual for related related to curriculum requirements, industry employment. An individual may supplement a degree or expectations, and the breadth and complexity other credential with one or more stackable of skills that the program is intended to instill. credentials.21 Stackable credentials may also be designed to help individuals adapt to a changing labor The length of the program may also be market while advancing their careers.22 affected by federal, state, and private entities that require a minimum number of educational hours to be eligible for employment, or for certification or licensing. The overall program duration may be broken up if it is designed in stackable units. A single educational program aligned to a career path may be redesigned into a sequence of independent programs (stackable units). Programs are offered in classrooms, online, by correspondence, with cooperative elements, or through a combination of methods. designated knowledge, skills, and abilities to perform a specific job; examples include Cisco certified network associate (CCNA) certification and medical technician certification. A license is an occupational credential awarded by a government agency that constitutes legal authority to do a specific job; examples include a medical license and an electrician’s license. NCES 2017-103rev, p. 1. 19 CRS calculations based on ED’s Integrated Postsecondary Education Data System (IPEDS) using the total of undergraduate non-degree/certificate-seeking students at Title IV-participating institutions in fall 2018. 20 The estimate was primarily based on state authorized postsecondary institutions that are not accredited. C. Goldin, S.R. Cellini, “Does Federal Student Aid Raise Tuition? New Evidence on For-Profit Colleges,” American Economic Journal: Economic Policy, 2014;6 (November):174-206, p. 16. 21 Research for Action, Research Brief: Measuring the Effects of Outcomes-Based Funding on Certificate Production: Challenges, Inconsistencies and Recommendations for Future Research, February 2019, pp. 4-5. 22 Evelyn Ganzglass, Scaling “Stackable Credentials”: Implications for Implementation and Policy, Center for Postsecondary and Economic Success, March 2014. Congressional Research Service 6 Direct Federal Support of Individuals Pursuing Training & Education Generally, students must fund or find funding for the cost of a program, and, if applicable, for related living expenses and lost wages for foregone employment. Program cost varies by length, program resource requirements, and provider. For example, for the most heavily enrolled programs in AY2018-2019, the average published cost for tuition and fees was over $9,000 at public less-than-two-year colleges and approximately $15,000 at private less-than-two-year colleges.23 Credit and Noncredit Programs In non-degree instructional programs, a dichotomy exists between programs made up of credit course(s) and those structured as a series of noncredit courses. However, courses in the same field of study with the same vocational objective and industry recognition may be offered for credit at one institution and noncredit at another, or even within the same institution.24 Generally speaking, individuals who successfully complete credit courses and programs earn credits that may be transferred or used as currency toward the completion of other credit programs (either at the conferring school or at another school). All degree programs are credit programs. Credit programs are most often approved by an accrediting entity and may have more stringent student entrance or prerequisite requirements. Credit programs may lead to a variety of vocations.25 Although noncredit programs may offer continuing education units (CEUs) or vocational certificates to program completers, the programs do not proffer these students currency toward the pursuit of credit programs or noncredit programs in other fields. The advantage of noncredit programs is that they often are less expensive for students and educational institutions, cover a broader range of topics, and can be modified more quickly to be attentive to industry and student needs.26 Noncredit programs may satisfy career entry requirements;27 may include adult basic education (ABE) and English as a second language (ESL) instruction; may provide personal enrichment; and may be customized training.28 Based on 2007-2013 enrollment information from 23 CRS calculations based on the published tuition and fees in AY2018-2019 for the largest program for full-time, first- time undergraduate students, averaged across the number of reporting institutions, from the Department of Education, Integrated Postsecondary Education Data System. A less-than-two-year college is a postsecondary institution that offers instructional programs of less than two years duration. 24 John Milam, “The Role of Noncredit Courses in Serving Nontraditional Learners,” New Directions for Higher Education, no. 129 (Spring 2005), p. 61. 25 Mark Schneider, Higher Education Pays: Measuring the Economic Security of Florida’s Postsecondary Graduates, College Measures, p. 31; and Di Xu and Xiaotao Ran, Noncredit Education in Community College: Students, Course Enrollments, and Academic Outcomes, Community College Research Center, Teachers College, Columbia University, CCRC Working Paper No. 84, September 2015, p. 12. 26 Di Xu and Xiaotao Ran, Noncredit Education in Community College: Students, Course Enrollments, and Academic Outcomes, Community College Research Center, Teachers College, Columbia University, CCRC Working Paper No. 84, September 2015, p. 1; and U.S. Government Accountability Office, Public Community Colleges and Technical Schools: Most Schools Use Both Credit and Noncredit Programs for Workforce Development, GAO-05-4, October 18, 2004, p.11. 27 Mark Schneider, Higher Education Pays: Measuring the Economic Security of Florida’s Postsecondary Graduates, College Measures, p. 24; and Di Xu and Xiaotao Ran, Noncredit Education in Community College: Students, Course Enrollments, and Academic Outcomes, Community College Research Center, Teachers College, Columbia University, CCRC Working Paper No. 84, September 2015, p. 12. 28 Di Xu and Xiaotao Ran, Noncredit Education in Community College: Students, Course Enrollments, and Academic Outcomes, Community College Research Center, Teachers College, Columbia University, CCRC Working Paper No. 84, September 2015, p. 8; and U.S. Government Accountability Office, Public Community Colleges and Technical Schools: Most Schools Use Both Credit and Noncredit Programs for Workforce Development, GAO-05-4, October 18, Congressional Research Service 7 Direct Federal Support of Individuals Pursuing Training & Education nine colleges in one state community college system, approximately 38% of enrollments were in noncredit courses: vocational (18%), ABE (9%), ESL (7%), and general educational development (GED) (4%).29 Participation Data National level data on the universe of non-degree instructional programs, enrollment, and completions are incomplete.30 Some states and the federal government do not collect data on noncredit programs.31 A 2016 nationwide survey found that 8% of adults aged 16-65 and not enrolled in high school had a postsecondary certificate, although some of these certificates may be postgraduate.32 The subset of educational institutions participating in the HEA Title IV federal student aid programs (see the “HEA Title IV Federal Student Aid” section below) awarded almost 1 million for-credit non-degree undergraduate credentials and approximately 3 million undergraduate degrees in AY2017-2018.33 Work-Based Learning Programs The term work-based learning refers to a range of training and educational activities that are intended to impart general or specific workplace skills to individuals through time spent at an employer’s worksite or a simulated work location. The terms defined in Table 2 are examples of common types of work-based learning in the federal context. Work-based learning is a broad term and may occur at multiple points in a career path and in multiple forms, ranging from career exploration for youth to highly specialized technical training for incumbent workers.34 Activities considered to be work-based learning include, but are not limited to, on-the-job training (OJT), apprenticeships, summer job experiences, internships, externships, residencies, cooperative programs (co-ops), and paid or unpaid work experiences. Programs that provide wages or remuneration are often referred to as earn and learn programs.35 Table 2. Examples of Work-Based Learning Type of Work-Based Learning Apprenticeship Description An arrangement that includes a paid-work component and an educational or instructional component, wherein an individual obtains workplace relevant knowledge and skills.a 2004. 29 Data on noncredit programs are not collected at a national level in part because the programs are not eligible for Title IV aid. Di Xu and Xiaotao Ran, Noncredit Education in Community College: Students, Course Enrollments, and Academic Outcomes, Community College Research Center, Teachers College, Columbia University, CCRC Working Paper No. 84, September 2015, p. 2, 8-9; and John Milam, “The Role of Noncredit Courses in Serving Nontraditional Learners,” New Directions for Higher Education, no. 129 (Spring 2005), p. 57. 30 Michelle Van Noy, Heather McKay, and Suzanne Michael, Non-Degree Credential Quality: A Conceptual Framework to Guide Measurement, Rutgers Education and Employment Research Center, July 2019, https://smlr.rutgers.edu/sites/default/files/rutgerseerc_ndcquality_framework_full_paper_final.pdf. 31 Jenna Leventoff, Measuring Non-Degree Credential Attainment, National Skills Coalition, May 2018, p. 2. 32 NCES 2017-103rev, p. 3. In the context of the Adult Training and Education Survey (ATES) of the National Household Education Surveys Program, 2016, “Adults are persons aged 16 to 65 and not enrolled in high school.” 33 CRS compiled data from the U.S. Department of Education, Integrated Postsecondary Education Data System (IPEDS). 34 Generally speaking, an incumbent worker is an existing employee with an employment history (20 C.F.R. §680.780). 35 38 C.F.R. §21.4233(a). Congressional Research Service 8 Direct Federal Support of Individuals Pursuing Training & Education Type of Work-Based Learning Description Cooperative program (co-op) A full-time program of education consisting of phases of school instruction alternated with training in a business or industrial establishment, with such training being strictly supplemental to the school instruction that may be approved.b Customized training Training that is designed to meet the specific requirements of an employer or group of employers; that is based on a commitment of an employer to employ, or continue to employ, an individual who successfully completes the training; and for which the employer pays a “significant” amount of its cost.c Incumbent worker training Training that is designed to meet the specific requirements of an employer or group of employers in order to retain employees or avert layoffs and is based on a commitment by the employer to retain the incumbent workers who successfully complete training.d Internship A planned, structured learning experience that takes place in a workplace for a limited period of time. Internships may be paid or unpaid.e On-the-job training (OJT) Paid, productive work experience offered by an employer or other industry-relevant entity intended to provide knowledge or skills essential to the full and adequate performance of the job for which training is provided. OJT may include theoretical and technical instruction.f Registered apprenticeship (RA) Apprenticeships that have been approved by the Department of Labor (DOL) or a DOL-approved state agency as meeting specified standards.g Sources: a. Department of Labor Task Force on Apprenticeship Expansion, Final Report of the Task Force on Apprenticeship Expansion, May 10, 2018, p. 40. b. 38 C.F.R. §21.4233(a). c. 20 C.F.R. §680.760. d. 20 C.F.R. §680.790. e. 20 C.F.R. §680.180. f. 29 U.S.C. §3102(44). g. For more information on RA, see CRS Report R44174, Apprenticeship in the United States: Frequently Asked Questions. Registered Apprenticeship (RA) RA programs are a distinctive form of work-based learning because of their DOL oversight.36 RA programs are registered with DOL or a DOL-approved state agency if they meet standards delineated in federal regulations. Among the requirements, a registration application must include a work process schedule, which outlines the major competencies of the occupation and how a combination of OJT and/or related instruction will lead to the worker demonstrating proficiency in those competencies. Once a program is registered, the registration agency must review the program no less than once every five years to ensure that it remains in compliance with the required standards. If the program demonstrates a “persistent and significant failure to perform successfully,” the program may be deregistered.37 36 For more information on RA programs, see CRS Report R45171, Registered Apprenticeship: Federal Role and Recent Federal Efforts. 37 See 29 C.F.R., Chapter 29 for more information on standards and deregistration. Congressional Research Service 9 Direct Federal Support of Individuals Pursuing Training & Education Providers Because work-based learning encompasses such a broad range of training activities, it is possible for multiple types of entities or individuals to offer such learning experiences. Work-based learning experiences may be provided by employers (either formally or informally), labor unions, external training providers, educational institutions providing work-relevant instruction, or partnerships of these entities. Structure, Duration, and Cost of Programs Work-based learning is generally structured to meet the needs of the employer, potential employer, or trainee. For example, summer internships may offer three to four months of informal training opportunities. Conversely, a summer internship may offer a formal curriculum covering specified procedures or tasks through iterative task-based coaching/instruction. RA programs require at least 2,000 hours of supervised OJT and range in duration from one to six years, but most RA programs are four years in duration.38 Some RA programs take a time-based approach through which an apprentice learns and obtains skills by completing a specified number of hours of OJT. Other programs take a competency-based approach in which skill attainment is verified by the apprentice demonstrating proficiency in the skill learned. Programs may also be constructed as hybrid programs that combine aspects of the time-based and competency-based approaches. All RA program designs must include related instruction to supplement OJT. The costs of work-based learning programs are primarily borne by the provider, but the trainee may be required to cover his/her living costs. Program costs may include the lost work time of experienced employees, fees for contracted trainers, and trainee wages. As the work-based learning progresses, some portion of the program costs may be offset by the trainee’s increased productivity. In some cases, trainees may be required to pay for related instruction or other costs. Work-based learners who do not receive remuneration or receive nominal remuneration must provide for their own transportation, room, and board while also potentially forgoing the opportunity to earn wages from other paid employment. Participation Data The data on work-based or employer provided training are not extensive. The data sets that do exist often differ in methodology, timeframe, and purpose. For example, some surveys look only at firms with 50 or more employees, while others are part of larger household surveys not designed around employer provided training questions. A summary of four different government surveys related to employer provided training in the 1990s concluded that while most establishments offer some training (formal or informal), the percentage of workers receiving training ranged from 16% to 70%.39 A 2016 nationwide survey found that 21% of adults aged 16-65 had completed a work-based learning program, although not all of these programs were intended to prepare individuals for a 38 See https://doleta.gov/OA/apprenticeship.cfm. 39 Robert I. Lerman, Signe-Mary McKernan, and Stephanie Riegg, “The Scope of Employer-Provided Training in the United States: Who, What, Where, and How Much?,” Job Training Policy in the United States, ed. Christopher J. O'Leary, Robert A. Straits, and Stephen A. Wandner (Kalamazoo, MI: W.E. Upjohn Institute for Employment Research, 2004), p. 222. Congressional Research Service 10 Direct Federal Support of Individuals Pursuing Training & Education particular occupation or field of work.40 Among adults aged 16-65, the most common work-based learning programs completed were in healthcare and teaching. 41 With respect to RA, DOL reported approximately 633,000 active apprentices in about 25,000 active programs in FY2019.42 In the same year, about 81,000 apprentices completed a program.43 The construction industry currently accounts for the largest share of apprenticeships, though they are available in other industries such as manufacturing and transportation.44 Federal Programs and Benefits The federal government provides direct financial support to individuals pursuing training and education that might better prepare them for entry into the workforce and that might help them realize their potential. None of the federal programs or benefits that provide such support focus exclusively on promoting training or education through the pursuit of non-degree programs. With that caveat in mind, federal programs are described below in an order that generally attempts to correspond to their relevance to supporting the pursuit of training or education through nondegree programs. The design and implementation of the federal programs and benefits are notably different in several aspects including, but not limited to, the choice and monitoring of non-degree programs. The primary benefit programs are the Workforce Innovation and Opportunity Act (WIOA) Title I program, the federal student aid programs, federal tax benefits, and veterans educational assistance. WIOA Title I, administered by the Department of Labor (DOL), is intended to encourage general workforce development and may be used to directly subsidize training costs of individuals who pursue training and education. The federal student aid programs, authorized under Title IV of the Higher Education Act (HEA) and administered by the Department of Education, provide grants and loans to students to aid them in accessing and completing postsecondary education programs. The Internal Revenue Service (IRS) administers the Internal Revenue Code, which, among other things, provides certain tax benefits as a strategy for posteducation financial support. Educational assistance administered by the Department of Veterans Affairs (VA), specifically the Post-9/11 GI Bill and Veteran Employment Through Technology Education Courses (VET TEC), are programs designed to provide direct financial support to students that allows them to pursue a wide variety of educational and training programs. Two programs that augment the basic living supports for needy families with some training and education assistance are also discussed in this report. Supplemental Nutrition Assistance Program (SNAP) Employment & Training (E&T), administered by the Department of Agriculture (USDA), provides training and education opportunities to individuals with a high risk for educational failure. Temporary Assistance for Needy Families (TANF), administered by the Department of Health and Human Services (HHS), provides flexibility to states to use TANF funds for activities that would develop a more highly skilled workforce through training and education. 40 NCES 2017-103rev, p. 3. 41 NCES 2017-103rev, p. 4. 42 U.S. Department of Labor, “Registered Apprenticeship National Results Fiscal Year (FY) 2019 (10/01/2018 to 9/30/2019),” https://doleta.gov/oa/data_statistics.cfm, downloaded on February 18, 2020. 43 Ibid 44 Ibid. Congressional Research Service 11 Direct Federal Support of Individuals Pursuing Training & Education The subsequent sections of this report describe these prominent federal programs that can be used to support students in non-degree programs. The sections are organized to focus on key program design elements and highlight differences among the programs. Table 3 highlights a few program characteristics that help to delineate key differences. Congressional Research Service 12 Table 3. Selected Characteristics of Federal Programs Supporting Students who Pursue Training or Education Through Non-degree Programs Federal program listed in order of report description Federal Program (Administering Agency) Payment or Tax Benefit Structure General Purpose Non-degree Programs Eligible Participantsa Workforce development. Primarily supports career services, but also training and training support services. Non-degree instruction. Adults over age 18 who need training to obtain or retain employment that leads to economic selfsufficiency. Funds disbursed to training providers. Only in-demand or potentially in-demand occupations. State and local workforce development boards establish criteria and procedures that meet WIOA minimums. Access to and affordability of the benefits of postsecondary education. Primarily support students pursuing degrees. For-credit instructional programs of at least 600 clock hours over 15 weeks offered by HEA Title IV-eligible IHEs.b Undergraduate students with financial need and no bachelor’s degree. State agency approval. Accrediting agency approval using HEA minimum criteria. ED certification. For-credit instructional programs of at least 300 clock hours over 10 weeks offered by HEA Title IV-eligible IHEs.b Undergraduate and graduate students, and parents of undergraduates. Funds disbursed to schools. Funds remaining after payment of institutional charges are remitted to student or parent. Lifetime Learning Credit (IRS) Offsets higher education costs, including those incurred to acquire or improve job skills. Non-degree instruction and work-based learning offered by HEA Title IVeligible IHEs. Eligible taxpayers (or their dependents) if income is below specified limits. Credit that reduces federal income tax liability. HEA Title IV institutional eligibility criteria. Employer Provided Assistance (IRS) Increased employee productivity.c Non-degree instruction and work-based learning. Employees of participating employers. Assistance not subject to federal payroll or income taxes. Employer judgment (to be eligible to be excluded from wages for tax purposes, employer provided educational assistance must be provided under a written educational assistance plan that must meet several requirements). WIOA Individual Training Accounts (DOL) WIOA Contracts (DOL) Pell Grants (ED) Direct Loans (ED) CRS-13 Work-based learning. Quality Assurance Federal Program (Administering Agency) General Purpose Non-degree Programs Eligible Participantsa Payment or Tax Benefit Structure Quality Assurance 529 Accounts (IRS) Encourages saving for educational expenses. Non-degree instruction and work-based learning offered by HEA Title IVeligible IHEs. Beneficiaries of established savings accounts. Tax-advantaged savings account. HEA Title IV institutional eligibility criteria. Post-9/11 GI Bill (VA) Adjustment to civilian life and civilian employment. Facilitating recruitment and retention in the uniformed services. Non-degree instructional programs, OJT, and RA. Veterans and servicemembers and their family members. Tuition and fees paid to educational providers. Housing allowances paid to participants. State agency approval, and state agency and VA reviews. Only non-degree high technology programs that are not offered by degree-granting colleges. GI Bill-eligible veterans. Supplemental Nutrition Assistance Program (SNAP) Employment & Training (E&T) (USDA) Providing employment and training opportunities for SNAP participants, particularly those subject to the work-related eligibility requirements. Non-degree instruction and work-based learning. SNAP participants (financial and other eligibility rules apply); E&T participants are typically those subject to work-related requirements. State agencies typically fund direct services or fund contracted partners to provide services. State agency monitoring with federal oversight. Temporary Assistance for Needy Families (TANF) (HHS) End government dependency of needy families and promote families living together. Primarily assistance for basic needs. Non-degree instruction and work-based learning. Parents or caretakers of TANF households. States may pay participants or service providers. State agency monitoring. VET TEC (VA) Incentive of 50% tuition and fees reimbursement upon participant employment, and VA-developed criteria. Source: Table prepared by CRS based on statutory provisions, regulations, and other published guidance. a. Additional eligibility rules apply. b. HEA Title IV-eligible IHEs are institutions of higher education that meet the eligibility requirements to participate in the HEA Title IV federal student aid programs. c. U.S. Congress, House Committee on Agriculture, Two-Year Extension of Exclusion with respect to Educational Assistance Plans, To accompany H.R. 2568, 98th Cong., 2nd sess., September 24, 1984, H.Rept. 98-1049, p. 7. CRS-14 Direct Federal Support of Individuals Pursuing Training & Education WIOA Contracts and Individual Training Accounts (ITAs) (DOL) Title I of the Workforce Innovation and Opportunity Act (WIOA; P.L. 113-128) is the primary federal workforce development legislation and is intended to bring about increased coordination among federal workforce development and related programs.45 WIOA Title I is administered by DOL and funded through discretionary appropriations. Services authorized under WIOA are intended to: increase the employment, retention, and earnings of participants, and increase attainment of recognized postsecondary credentials by participants, and as a result, improve the quality of the workforce, reduce welfare dependency, increase economic self-sufficiency, meet the skill requirements of employers, and enhance the productivity and competitiveness of the Nation.46 The Adult and Dislocated Worker Employment and Training Activities program under WIOA Title I provides formula grants to states, which in turn allocate the majority of those funds to local Workforce Development Boards (WDBs). At the local level, funds are required to be used for five main purposes: establishing a One-Stop delivery system, providing career services, providing training services, establishing relationships with employers, and developing industry or sector partnerships.47 As part of its service delivery model, WIOA Recognized Postsecondary Credential provides consumer choice to participants. The A recognized postsecondary credential is an program for adult and dislocated worker industry-recognized certificate, certification, participants in WIOA is structured around two certificate of completion of an apprenticeship, license main levels of services: career services and recognized by the state or federal government, or associate’s or baccalaureate degree.48 training. On an operational level, career services are categorized as basic and individualized. Basic services include assistance such as labor market information and job postings, while individualized services include assistance such as skills assessment and case management. Eligibility of Non-degree Programs Eligible WIOA participants may pursue training and education at the eligible training provider (ETP) of their choice. A state Eligible Training Provider List (ETPL) identifies choices to customers who are accessing WIOA services. Generally, ETPs include the following:    institutions of higher education that are eligible to participate in the HEA Title IV federal student aid programs and offer programs leading to a recognized postsecondary credential, entities that provide RA, or other public or private training providers.49 45 29 U.S.C., Chapter 32; and 20 C.F.R., Parts 678 and 680. 46 29 U.S.C. §3101(6). 47 34 C.F.R. §668.32. 48 29 U.S.C. §3102(52). 49 The term training provider is not defined in WIOA. However, 20 C.F.R. §680.410 notes that in addition to institutions of higher education and apprenticeship programs, other providers of training services may include community-based organizations and joint labor-management organizations. Congressional Research Service 15 Direct Federal Support of Individuals Pursuing Training & Education Allowable training activities that may be supported with WIOA Title I funds are non-degree and degree instructional programs and certain types of work-based learning, including OJT, RA, customized training, and incumbent worker training. Training must be for occupations that are in demand in the local area or region, are in demand in an area to which the trainee is willing to relocate, or are deemed (by the local WDB) to have “high potential for sustained demand or growth in the local area.”50 In addition, the implementing regulations for WIOA specify that a program of training services provided by an ETP is one or more courses or classes or a structured regimen that leads to the following:       an industry-recognized certificate or a certificate of completion of an RA, a license recognized by the state or federal government, an associate or baccalaureate degree, a secondary school diploma or equivalent, employment, or measurable skill gains toward a credential. Local areas under WIOA may reserve up to 20% of combined adult and dislocated worker funds for incumbent worker training. Participant Eligibility for Training The workforce development system designed by WIOA is premised on universal access, such that an adult age 18 or older who is a citizen or noncitizen authorized to work in the United States does not need to meet any qualifying characteristics in order to receive career services.51 While basic career services are available to all adults, individualized career services are to be provided as appropriate to help individuals obtain and retain employment. Under WIOA, service at one level is not a prerequisite for service at the next level. To be eligible to receive training, an individual must      be unlikely or unable to obtain or retain employment that leads to economic selfsufficiency,52 be in need of training services to obtain or retain employment that leads to economic self-sufficiency, have the skills and qualifications to participate successfully in training, select a training service linked to an occupation in the local area (or be willing to relocate to another area where the occupation is in demand), and be unable to obtain other grant assistance (e.g., Pell Grants) for the training services. These determinations are made by a One-Stop operator through an interview, evaluation, or assessment, which can include a recent evaluation or assessment conducted pursuant to another education or training program. Local WDBs designate colleges and universities, private 50 29 U.S.C. §3174(c)(3)(G)(iii). 51 To participate in WIOA services, an individual must not be in violation of Section 3 of the Military Selective Service Act (i.e., must be registered for military service). 29 U.S.C. §3249(h). 52 Economic self-sufficiency is not defined in WIOA. However, 29 U.S.C. §3174(d)(1)(A)(x) allows local funds to be used to adjust the economic self-sufficiency standards for local factors or to calculate and adopt local self-sufficiency standards. Congressional Research Service 16 Direct Federal Support of Individuals Pursuing Training & Education organizations, and government agencies as One-Stop operators that assess and evaluate individuals and decide which individuals to provide with access to training services. Of funds allocated to a local area for adult employment and training activities, priority for career and training services is to be given to recipients of public assistance, other low-income individuals, and individuals who are basic skills deficient. It is left to the discretion of the local WDB, in consultation with the state’s governor, to determine how to allocate funds among these priority groups. Basic Benefit Payment Structure Under WIOA, training is allowed through ITAs or through contracts for services. While ITAs are the primary vehicle, contracts may be used in certain circumstances.53 WIOA also permits funds to be used for supportive services (e.g., child care and transportation) and “needs-related payments” necessary to enable an individual to participate in training. When an individual is determined by a One-Stop operator to be eligible to receive training services, that individual, in consultation with the One-Stop operator, may choose training services from the ETPL. At that point, an ITA is established, from which payment is made to the ETP, not to the individual, for training services. Local WDBs have the authority to set limits on the type and duration of training and may choose to set limits on the amount of an ITA, based on individual circumstances or on an across-the-board level. WIOA participants who are in receipt of an ITA may use ITA funds to support non-degree instructional and degree programs and the related instruction portion of an RA. In addition, local WDBs are also authorized to provide supportive services, including transportation, child care, dependent care, housing, and needsrelated payments necessary to enable an individual to participate in training. While training is typically carried out through the ITA model, local WDBs may provide training through a contract for services, which may include various forms of work-based learning.54 The contract is an agreement between a local WDB and an employer or RA sponsor for occupational training for a WIOA participant in exchange for reimbursement from the WDB. A contract for services may be used if       the consumer choice requirements of WIOA are met; the services are OJT, RA, customized training, incumbent worker training, or transitional employment; the local WDB determines there is an insufficient number of training providers in a local area to meet the ITA requirements; the local WDB determines there is a local training program of demonstrated effectiveness to serve individuals with barriers to employment; the local WDB determines that it is most appropriate to contract training services to train multiple individuals in in-demand occupations or industry sectors; or the training service is a pay-for-performance contract. For example, through a contract, a local WDB may reimburse an OJT provider (employer) for up to 50% of the wage rate of a participant (reimbursement rates may be 75% in limited circumstances). State and local WDBs may also enter into contracts with RA sponsors to 53 Byron Zuidema, Deputy Assistant Secretary, Advisory: Training And Employment Guidance Letter WIOA No. 19-16 Operating Guidance for the Workforce Innovation and Opportunity Act, Department of Labor, Employment and Training Administration, March 1, 2017, p. 7. 54 WIOA allows for alternative mechanisms authorized under 29 U.S.C. §3174(c)(3)(G)(ii). Congressional Research Service 17 Direct Federal Support of Individuals Pursuing Training & Education reimburse the sponsors for up to 75% of an apprentice’s wages. Notably, reimbursement for wages is supported by a contract, not an ITA. Basic Administrative Structure As noted, states are responsible for developing the ETPL. Local WDBs and One-Stop operators administer the training programs and payments to training providers. Thus, administrative structures and procedures vary by state. Quality Assurance Mechanisms Quality assurance of training providers is established through both initial and continued provider eligibility processes. The governor and the state WDB in each state are responsible for establishing criteria and procedures for eligible providers of training services to receive funding in the local workforce investment areas. RA programs are automatically eligible to be included on the state ETPL.55 Non-RA training providers not previously eligible under WIOA or its predecessor law must apply to the governor and the local WDB (according to a procedure established by the governor) for initial eligibility of one fiscal year. To maintain continued eligibility, existing training providers must follow procedures established by the governor and implemented by the local WDB and submit WIOA-specified information. WIOA provides general requirements while allowing local WDBs discretion on specific factors. For example, while WIOA indicates that OJT contracts should be limited in duration, as appropriate to the occupation, the training content, and the participant’s prior work experience and service strategy, the exact length of the OJT contract is determined by the local WDB. Similarly, WIOA requires that in determining employer eligibility to receive WIOA incumbent worker training funding, a local WDB must consider the characteristics of individuals in the program and the relationship of the training to the competitiveness of the individual and the employer without establishing quantifiable targets. Measures of Program Performance WIOA requires ETPs and states to report measures of program participation and outcomes. Notably, RA programs are not required to submit ETP performance report information.56 To be considered for continued eligibility, providers must submit to the governor every two years the following performance and cost information for participants receiving training under WIOA Title I:57  the percentage of program participants in unsubsidized employment in the second and fourth quarters after program exit; 55 The governor must inform all RA programs in the state of this automatic eligibility and must provide an opportunity to RA programs to consent to inclusion on the state ETPL. See 20 C.F.R. §680.470. 56 20 C.F.R. §677.230(b). The regulations note that although RA programs are not required to submit ETP performance report information, these programs may voluntarily submit performance information, and that states are required to include such information (if submitted) in ETP reports. As DOL notes, this exemption for RA programs from ETP performance reporting exists because “all apprenticeship programs registered with a recognized State Apprenticeship Agency or the USDOL Office of Apprenticeship undergo a rigorous application and vetting process in order to become registered by the apprenticeship system.” See U.S. Department of Labor, Registered Apprenticeships and the Eligible Training Provider (ETP) List - FAQs, Washington, DC, May 2016, p. 5, https://www.dol.gov/apprenticeship/docs/ ETPL_FAQ_Workforce_System.pdf. 57 WIOA §122(b)(2). The required information from training providers is for WIOA-funded participants only, not for individuals otherwise participating in the training provider’s program. Congressional Research Service 18 Direct Federal Support of Individuals Pursuing Training & Education      median earnings of program participants who are in unsubsidized employment during the second quarter after program exit; the percentage of program participants who obtain a recognized postsecondary credential, or secondary school diploma or equivalent, during participation or within one year of program exit; information on the type of recognized postsecondary credentials received by program participants; information on the cost of attendance, including tuition and fees, for program participants; and information on program completion rates for program participants. In addition, the governor may require additional, specific performance information deemed necessary to determine continued eligibility. States are required to publish and disseminate annual ETP performance reports. The reports must include the following information with respect to each program of study eligible to receive WIOA funds, disaggregated by the type of entity that provided the training, during the most recent program year and the three preceding program years:    the total number of participants who received training services through a WIOA Title I program, the total number of participants who exited from training services, and the average cost per participant for the participants who received training services. In addition, the ETP performance reports must include the number of participants with barriers to employment served by the WIOA Title I programs, disaggregated by each program of study eligible to receive WIOA funds and each subpopulation of such individuals, and by race, ethnicity, sex, and age.58 Program Participation The first WIOA ETP performance report is not yet available, but some participation data are available.59 Within the WIOA-authorized forms of work-based learning, the most recent data available (2017) indicate 955,094 adult participants and 469,572 dislocated worker participants. The majority of participants are age 30 and over (67% of adults and 82% of dislocated workers) and unemployed or have received a layoff notice (82% of adults and 92% of dislocated workers). While many participants had no postsecondary education experience (59% of adults and 47% of dislocated workers), a notable 22% of adults and 34% of dislocated workers had a degree.60 58 20 C.F.R. §677.230; Rosemary Lahasky, Eligible Training Provider (ETP) Reporting Guidance under the Workforce Innovation and Opportunity Act (WIOA), U.S. Department of Labor, Employment and Training Administration, Training and Employment Guidance Letter No. 3-18, Washington, DC, August 31, 2018, http://wdr.doleta.gov/ directives/attach/TEGL/TEGL_3-18.pdf. 59 Rosemary Lahasky, Eligible Training Provider (ETP) Reporting Guidance under the Workforce Innovation and Opportunity Act (WIOA), U.S. Department of Labor, Employment and Training Administration, Training and Employment Guidance Letter No. 3-18, Washington, DC, August 31, 2018, http://wdr.doleta.gov/directives/attach/ TEGL/TEGL_3-18.pdf, p. 7. 60 U.S. Department of Labor, Employment and Training Administration, Office of Policy Development and Research, PY2017 Quarter 3 Report for WIOA and Wagner-Peyser, Washington, DC, July 2018, https://www.doleta.gov/ performance/results/docs/WIOA_Performance/PY2017/Q3/WIOA_and_Wagner-Peyser_PY2017Q3.pdf. Congressional Research Service 19 Direct Federal Support of Individuals Pursuing Training & Education Table 4 shows usage of training services among program exiters in program year 2018. Fewer than 20% of WIOA Title I participants engage in work-based learning provided under contract. The majority, over 66%, of trainees pursue skills training or upgrading through non-degree instructional and degree programs with ITAs. The most popular occupations pursued by adults through training were healthcare, transportation and material moving, and production. The most popular occupations pursued by dislocated workers were transportation and material moving, computer and mathematical, office and administrative support, and management. Table 4. Percentage of WIOA Title I Program Exiters, by Training Type PY2018 (July 1, 2018–June 30, 2019) Services Number of trainees Adults Dislocated Workers 85,705 38,216 Occupational skills traininga 66% 72% Skill upgradinga 14% 16% OJT, excluding RA 14% 9% Customized training 3% 1% RA 2% 1% Source: U.S. Department of Labor, Employment and Training Administration, Office of Policy Development and Research, PY2018 Data Book, Washington, DC, February 2020, Tables II-13 and III-14, https://www.doleta.gov/ performance/results/WIASRD/PY2018/PY_2018_WIOA_and_Wagner-Peyser_Data_Book.pdf . Notes: Percentages do not add to 100%, as participants may receive training of more than one type listed and/or other types not listed. a. There is no clear distinction between skill upgrading and other occupational skills training. Program Limitations WIOA Title I currently supports adult entry or reentry into the workforce primarily by providing career services, but short-term training and education are also provided. The program assumes that many participants only need career services. Support for non-degree training and education pursuits could be bolstered by the following:   increasing focus of One-Stop operators to increase access to non-degree training; additional funding could be dedicated to wage reimbursement and/or ITAs to ensure the availability of career services;  the 20% limit on incumbent training could be relaxed to ensure current workers remain employed despite changing skill requirements, and  the restriction on recipients of training services being able to obtain other grant assistance (e.g., Pell Grants) could be eliminated to allow programs to supplement one another. Non-degree program quality may vary given state and local flexibility in developing the ETPL. HEA Title IV Federal Student Aid (ED) Title IV of the Higher Education Act (HEA; P.L. 89-329, as amended), authorizes programs that provide financial assistance to students to promote access to, affordability, and completion of higher education at certain institutions of higher education (IHEs). The programs are Congressional Research Service 20 Direct Federal Support of Individuals Pursuing Training & Education administered by the Department of Education. Grants are available to qualified, financially needy students, and loans are available to qualified borrowers (both students and parents of dependent students). The primary types of Title IV aid are Federal Pell Grants61 and federal student loans made through the William D. Ford Federal Direct Loan (Direct Loan) program.62 The Pell Grant and Direct Loan programs are designed to provide portable aid (i.e., the availability of aid follows students to the eligible postsecondary education institutions in which they choose to enroll). Title IV also authorizes other aid programs that are relatively smaller in scale and thus are not discussed in this report.63 Pell Grants and Direct Loan program loans are available to all eligible individuals regardless of congressional appropriations. The Direct Loan program is a mandatory entitlement program for budgetary purposes. As a mandatory entitlement, all eligible individuals have access to borrow in accordance with program rules, and the requisite budget authority is available. The Pell Grant program is often referred to as a quasi-entitlement because eligible students receive the Pell Grant award to which they are entitled regardless of discretionary appropriations levels.64 Eligibility of Non-degree Programs Pell Grants and Direct Loans may be used to pursue Title IV-eligible programs of study, which include non-degree instructional and degree programs and some work-based learning. Title IVeligible programs must be offered by Title IV-participating IHEs. To be eligible, programs and Title IV-participating IHEs must meet a variety of criteria, including quality assurance (see the “Quality Assurance Mechanisms” section). Title IV-participating IHEs are classified as public IHEs, private nonprofit IHEs, proprietary (private for-profit) IHEs, and public and private nonprofit postsecondary vocational institutions.65 Non-degree programs must meet several eligibility requirements.66 For example, in general, the Title IV-eligible non-degree instructional program and the Title IV-eligible portion of work-based learning must lead to a certificate or other recognized non-degree credential (e.g., diploma or license). Also, Title IV aid is generally not available for noncredit programs or portions of programs for which a defined number of credit or clock hours is not associated.67 For instructional and work-based learning programs measured in clock hours, the OJT portion of work-based learning must be offered under the supervision of an IHE. If a portion of the OJT is 61 For additional information, see CRS Report R45418, Federal Pell Grant Program of the Higher Education Act: Primer. 62 For additional information, see CRS Report R45931, Federal Student Loans Made Through the William D. Ford Federal Direct Loan Program: Terms and Conditions for Borrowers. 63 For information on these programs, see CRS Report RL31618, Campus-Based Student Financial Aid Programs Under the Higher Education Act; and CRS Report R46117, TEACH Grants: A Primer. 64 The Pell Grant program is funded through a mix of discretionary and mandatory appropriations. 65 Any public or private nonprofit institution, including those that award degrees, may act as postsecondary vocational institutions. 66 For additional information, see 2019-2020 Federal Student Aid Handbook (hereinafter, FSA Handbook), vol. 1, pp. 4-5 and vol. 2, pp. 27-33. 67 Students enrolled in a Title IV-eligible program may be eligible for up to one academic year of noncredit remedial courses; English as a Second Language courses without time limitations; and, for Direct Loan purposes, up to one year of coursework necessary for enrollment in a Title IV-eligible program. 34 C.F.R. §§668.32, 600.2; FSA Handbook, vol. 1, pp. 19-20, 25. Congressional Research Service 21 Direct Federal Support of Individuals Pursuing Training & Education offered by an entity under contract with an IHE, such portion must be less than 50% of the program.68 In general, non-degree programs are subject to specific durational requirements,69 including weeks of instructional time70 and number of credit or clock hours. For Pell Grants, the non-degree programs offered by public and private nonprofit postsecondary vocational institutions and proprietary institutions must either be   at least 15 weeks of instructional time and at least one of the following: 600 clock hours, 16 semester hours, or 24 quarter hours;71 or at least 10 weeks of instructional time and at least one of the following: 300 clock hours, 8 semester hours, or 12 quarter hours.72 For the Direct Loan program, non-degree programs offered by public and private nonprofit postsecondary vocational institutions and proprietary institutions must be at least 10 weeks of instructional time and 300-599 clock hours.73 In addition, students must be enrolled in an eligible program of study on at least a half-time basis to borrow through the Direct Loan program. See the text box below for information on an ED experiment with shorter duration programs. Pell Grant Experiment for Shorter Duration Programs HEA Section 487A authorizes ED to waive certain HEA Title IV requirements for selected IHEs to evaluate the impact or effectiveness of policy proposals; this is known as the Experimental Sites Initiative (ESI). From approximately 2012 to 2017, ED implemented an experiment allowing select IHEs to offer Pell Grants to otherwise-eligible students enrolled in a vocational program of at least eight weeks in length and 150-599 clock hours of instructional time.74 The 150-599 clock-hour programs had to meet the hiring requirement of multiple employers; meet local or regional workforce needs, as determined through consultations with employers or state and local workforce agencies; and allow students to obtain required licensure or certification. ED ended the experiment on June 30, 2017, because participation and data collection was insufficient to rigorously evaluate the value of the expansion in increasing employment or wages.75 Nevertheless, an evaluation report is expected in early fall 2020.76 68 For additional information on work-based learning, see FSA Handbook, vol. 2, p. 31; and Department of Education, Apprenticeship and the Federal Student Aid Programs, GEN-14-22, December 18, 2014. 69 Additional or alternative program eligibility requirements also apply to a variety of specific programs (e.g., those that consist solely of English as a second language or teacher certification programs). For additional information, see FSA Handbook, vol. 1, pp. 4-5 and vol. 2, pp. 27-33. 70 For additional information on the definition of academic year and weeks of instructional time, see FSA Handbook, vol. 3, pp. 3-7. 71 These programs may admit as regular students those who have not completed the equivalent of an associate’s degree. 72 These programs must admit as regular students only those who have completed the equivalent of an associate’s degree. 73 This type of program is known as a short-term program and is only eligible to participate in the Direct Loan program. The program must (1) admit as regular students some individuals who have not completed the equivalent of an associate’s degree, (2) have been in existence for at least one year, (3) have verifiable completion and placement rates of at least 70%, and (4) not be more than 50% longer than the minimum training period required by the state or federal agency (if any) for the occupation for which the program is intended. 74 U.S. Department of Education, Office of Postsecondary Education, “Postsecondary Educational Institutions Invited To Participate in Experiments Under the Experimental Sites Initiative,” 76 Federal Register 66698-66707, October 27, 2011. 75 National Association of Student Financial Aid Administrators, “Experimental Sites Initiative Closing Four Experiments,” press release, March 30, 2017, https://www.nasfaa.org/news-item/11682/ Experimental_Sites_Initiative_Closing_Four_Experiments. 76 U.S. Department of Education, Institute of Education Sciences, “Evaluation of the Pell Grant Experiments Under the Congressional Research Service 22 Direct Federal Support of Individuals Pursuing Training & Education Non-degree programs at public and private nonprofit IHEs that are at least one academic year in length and lead to a certificate or other recognized non-degree credential are eligible for both the Pell Grant and Direct Loan programs, without regard to any of the above-specified durational requirements. Participant Eligibility For a student to be eligible to receive Title IV funds for his or her higher education, he or she must be enrolled (or accepted for enrollment) in a Title IV-eligible program. In addition, among other criteria, a student must   be a U.S. citizen, national, legal permanent resident, or other specified eligible noncitizen;77 and have a high school diploma (or equivalent, such as a general educational development [GED] certificate) or meet other relevant criteria.78 Individuals must also meet program-specific eligibility criteria to receive Pell Grants or Direct Loan program loans. Pell Grant Program-Specific Eligibility Criteria To receive Pell Grants, students must meet program-specific criteria that include the following:    being enrolled in an undergraduate program, not having completed the curriculum requirements of a bachelor’s degree, and79 demonstrating financial need (primarily individuals from families in the two lowest income quintiles as determined under the program’s award rules).80 All recipients are subject to a cumulative lifetime eligibility cap on Pell Grant aid of 12 full-time semesters (or the equivalent). Direct Loan Program-Specific Eligibility Criteria To receive Direct Loan program loans, students must meet program-specific criteria81 that include being enrolled on at least a half-time basis.82 Students (or their parents in the case of PLUS Loans Experimental Sites Initiative,” https://ies.ed.gov/ncee/projects/evaluation/pathways_pell.asp, as available on March 20, 2020, https://ies.ed.gov/ncee/projects/evaluation/pathways_pell.asp. 77 Those noncitizens eligible to receive federal student financial aid are listed in U.S. Department of Education, Federal Student Aid, “Many non-U.S. citizens qualify for federal student aid,” http://studentaid.ed.gov/eligibility/non-uscitizens. 78 Such other criteria may include, but is not limited to, completing an eligible homeschool program or enrolling in a program that leads to both a high school diploma (or equivalent) and a recognized postsecondary credential. For more information and other generally applicable Title IV eligibility requirements for students, see FSA Handbook, vol. 1. 79 Students enrolled on at least a half-time basis in a post-baccalaureate program required by a state for K-12 teacher certification or licensure are also eligible, as long as the program does not lead to a graduate degree and the enrolling institution does not offer a baccalaureate degree in education. 80 Congressional Budget Office (CBO), Distribution of Federal Support for Students Pursuing Higher Education in 2016, 53732, June 2018, https://www.cbo.gov/system/files/2018-06/53732-taxexpenditureshighereducation.pdf. 81 See HEA §§427-428B, 455. For additional information, see CRS Report R45931, Federal Student Loans Made Through the William D. Ford Federal Direct Loan Program: Terms and Conditions for Borrowers. 82 Half-time enrollment is defined as taking at least half of the academic workload of a full-time student, as defined by Congressional Research Service 23 Direct Federal Support of Individuals Pursuing Training & Education to parents borrowing on behalf of a dependent child) may need to meet additional eligibility criteria to qualify for specific Direct Loan program loan types. The primary loans are the following:    Direct Subsidized83 Loans for undergraduate students with demonstrated financial need,84 Direct Unsubsidized Loans for any student regardless of financial need, and PLUS Loans for parents of dependent undergraduate students and graduate and professional students regardless of financial need. Individuals who are new borrowers on or after July 1, 2013, may only borrow Direct Subsidized Loans for a period of time not to exceed 150% of the published length of their academic program. Basic Benefit Payment Structure In general, the amount of Title IV aid for which a student is eligible is guided by statutory award rules. Aggregate Title IV aid and other aid (e.g., institutional aid) typically cannot exceed a student’s cost of attendance (COA). The COA is an institutionally determined measure of a student’s educational expenses for the period of enrollment and generally includes items such as tuition and fees; an allowance for books and supplies; and, as applicable, an allowance for room and board. The COA may also include transportation costs and dependent care expenses. An important feature of the Pell Grant award rules is that the grant is determined without consideration of any other financial assistance a student may be eligible to receive or may be receiving. Annual appropriations acts and the HEA establish the total maximum Pell Grant award amount that a student may receive in an academic year. For award year (AY) 2020-2021, the maximum Pell Grant award that an eligible individual enrolled full-time for a 26-30 week academic year may receive will be $6,345.85 The amount may be reduced based on the student’s COA, financial need, enrollment rate, or program duration. Pell Grant awards used to pursue nondegree programs are generally subject to income taxation; whereas Pell Grant awards used to pursue degree programs are only subject to income taxation if used for purposes other than tuition and fees.86 Direct Loan program award rules vary by type of loan borrowed. In addition, numerous other factors could affect the type and amount of aid awarded. However, some generally applicable rules apply to the Direct Loan program. Other types of financial assistance awarded to the student must be taken into account when awarding Direct Loan program loans. Also, an individual cannot be awarded a Direct Subsidized Loan or Direct Unsubsidized Loan in an amount that exceeds statutory annual and aggregate award limits, which are determined based on an individual’s the IHE and pursuant to minimum statutory and regulatory requirements. For example, for a student enrolled at an IHE that measures progress in credit hours and uses standard terms (e.g., semesters, trimesters, or quarters), he or she must be enrolled in six credit hours to be considered half-time. 34 C.F.R. §668.2(b). 83 With certain exceptions, the federal government subsidizes these loans by paying the interest that accrues on them while the borrower is enrolled in an eligible program on at least a half-time basis and during grace periods and periods of authorized deferment. 84 Individuals who are new borrowers on or after July 1, 2013, may only borrow Direct Subsidized Loans for a period of time not to exceed 150% of the published length of their academic program. 85 U.S. Department of Education, Department of Education Budget Tables, FY 2020 Congressional Action, last updated February 10, 2020, available at https://www2.ed.gov/about/overview/budget/budget20/20action.pdf. 86 26 U.S.C. §117. Congressional Research Service 24 Direct Federal Support of Individuals Pursuing Training & Education dependency status and class level.87 For example, a dependent undergraduate student may borrow up to $5,500 in Direct Subsidized Loans and Direct Unsubsidized Loans for his or her first year, while an independent undergraduate student may borrow up to $9,500 in such loans in his or her first year.88 The annual maximum loan amount an undergraduate student may receive is prorated when the borrower is enrolled in a program that is shorter than a full academic year. Basic Administrative Structure ED’s Office of Federal Student Aid (FSA) is the primary entity responsible for administering the Title IV aid programs. The administrative tasks associated with the programs are completed by a number of actors (e.g., FSA, IHEs), depending on the function.89 FSA undertakes many high-level functions in Title IV program administration.90 These include, but are not limited to, contracting for the operation and maintenance of systems to process aid; providing customer service, training, and user support for the administration of the programs; and ensuring integrity of the programs. IHEs complete many of the day-to-day functions associated with awarding and disbursing Title IV aid to students. ED makes funds available to IHEs so that they can disburse awards to students. IHE functions include verifying a student’s eligibility to receive the aid, calculating aid amounts,91 disbursing aid funds, and managing program funds at the institutional level.92 In addition, under the Pell Grant program ED pays participating IHEs an administrative cost allowance.93 Quality Assurance Mechanisms Several HEA provisions intended to ensure the quality of Title IV-eligible programs and Title IVparticipating IHEs have been enacted to protect students and taxpayers. The program integrity triad—state authorization, accreditation, and ED certification—is the foundation of these provisions and is intended to provide a balance in the Title IV eligibility requirements. State authorization is intended to provide consumer protection, accreditation is intended to provide quality assurance, and ED certification is intended to provide direct oversight of compliance in the Title IV programs.94 In addition to the requirements of the program integrity triad, non-degree programs may be required to meet gainful employment requirements. The following subsections 87 For additional information, see CRS Report R45931, Federal Student Loans Made Through the William D. Ford Federal Direct Loan Program: Terms and Conditions for Borrowers. 88 In either case, a first-year student may borrow no more than $3,500 in Direct Subsidized Loans. 89 For additional information on administration of the Direct Loan program, see CRS Report R44845, Administration of the William D. Ford Federal Direct Loan Program. 90 HEA §141; see also CRS Report R46143, The Office of Federal Student Aid as a Performance-Based Organization. 91 The process of calculating and determining the amounts and types of aid that will be offered to a student, in accordance with federal student aid need analysis procedures and individual programs rules, is called packaging. The packaging of aid may affect the types and amounts of aid that are made available to students. 92 Within the DL program, additional administrative tasks, such as collecting loan payments, are undertaken by contracted loan servicers. Within many of the other Title IV programs, additional tasks, such as attempting to collect on past-due Title IV balances owed to ED, are undertaken by other parties such as contracted entities and other federal agencies. 93 See 34 C.F.R. §690.10. 94 For additional information on institutional Title IV eligibility requirements, see CRS Report R43159, Institutional Eligibility for Participation in Title IV Student Financial Aid Programs. Congressional Research Service 25 Direct Federal Support of Individuals Pursuing Training & Education briefly describe each piece of the triad and the gainful employment requirements as they relate to Title IV-eligible programs. State Authorization An IHE must be authorized to provide a postsecondary education within the state in which it is located to participate in the Title IV programs, which includes complying with any applicable state approval or licensure requirements.95 State approval and licensure requirements vary appreciably among the states.96 For instance, some states approve IHEs and their individual educational programs, while other states only require approval of an IHE as a whole.97 The degree to which a state evaluates an individual educational program may also vary by state. For example, states variously evaluate program curricula, program objectives, projected enrollment, student outcome measurements (e.g., completion and placement rates), and justification of program need (e.g., industry demand or consumer interest).98 In addition, some states require programmatic accreditation (discussed below) or separate approval by another state agency (e.g., a professional licensing agency).99 Accreditation100 To participate in Title IV programs, an IHE must be accredited by an accrediting agency recognized by ED as a reliable authority of the quality of the education being offered.101 Accrediting agencies are private associations of member educational institutions or industry associations that undertake quality review of educational institutions and/or programs. In general, an IHE need only be accredited by a regional or national accreditor to participate in Title IV programs. The regional or national accreditor must evaluate whether the IHE meets accrediting agency-prescribed criteria. Although these criteria vary among the agencies, EDrecognized accrediting agencies must regularly102 evaluate statutorily specified areas, including 95 34 C.F.R. §600.9. 96 For an overview of the various state authorization requirements for IHEs, see Andrew P. Kelly and Rooney Columbus, Inputs, Outcomes, Quality Assurance: A Closer Look at State Oversight of Higher Education, American Enterprise Institute, August 2015, https://www.aei.org/research-products/report/inputs-outcomes-quality-assurance-acloser-look-at-state-oversight-of-higher-education/ (Hereinafter referred to as “Inputs, Outcomes, Quality Assurance”). 97 See, for example, State Higher Education Executive Officers Association, “SHEEO State Authorization Survey, Analysis of selected data elements for 50 U.S. States and D.C.,” October 2012, p. 4. 98 See, for example, Arkansas Higher Education Coordinating Board, Policy 5.11, “Approval of New Degree Programs and Units,” https://static.ark.org/eeuploads/adhe/New_Academic_Programs.pdf; Wisc. Stat. §440.52(7); State of Wisconsin, Educational Approval Program, “Program Application,” EAP Form 1.03, rev. January 2018, https://dsps.wi.gov/Documents/EAProgramApplication1.03.doc; 5 CCR §74112; Arkansas Higher Education Coordinating Board, Policy 5.11, “Approval of New Degree Programs and Units,” https://static.ark.org/eeuploads/adhe/ New_Academic_Programs.pdf; Kansas Board of Regents, Board Policy Manual, Chapter III: Coordination of Institutions, §5, https://www.kansasregents.org/about/policies-by-laws-missions/board_policy_manual_2/ chapter_iii_coordination_of_institutions_2/chapter_iii_full_text#programs; and W.Va. CSR §135-11-1 et seq; and Wisc. Stat. §440.52. 99 See, for example, State Higher Education Executive Officers Association, “SHEEO State Authorization Survey, Analysis of selected data elements for 50 U.S. States and D.C.,” October 2012, pp. 7-9; and 18 VAC 90-30-80, 18 VAC 90-30-10. 100 Large portions of this section are derived from CRS Report R43826, An Overview of Accreditation of Higher Education in the United States. 101 Public and private nonprofit IHEs and postsecondary vocational institutions may also be preaccredited. 102 Institutional accreditation may be renewed every few years to every 10 years, but IHEs are often required to submit periodic reports to accrediting agencies for continual evaluation. For more information, see Middle States Commission Congressional Research Service 26 Direct Federal Support of Individuals Pursuing Training & Education an IHE’s faculty, curricula, facilities, student support services, and success with respect to student achievement in relation to the institution’s mission. Within these broadly outlined criteria, accrediting agencies have discretion as to the precise evaluation measures. Regional and national accreditors evaluate an IHE’s performance on the whole, but may choose to evaluate a sample of programs. An educational program does not need to be accredited by a programmatic accrediting agency for Title IV purposes.103 However, an IHE may seek programmatic accreditation to satisfy employer and some occupational licensure requirements. To gain programmatic accreditation, an educational program offered by an IHE is evaluated on established standards for the particular field of study, such as whether the curriculum meets professional guidelines. ED Certification When an IHE seeks to participate in Title IV programs, it must apply for certification from ED. During this process, ED evaluates whether the IHE meets Title IV participation requirements. ED reviews each educational program to determine whether it satisfies eligibility requirements.104 For example, the eligibility requirements include the aforementioned durational requirements; and 300-599 clock-hour programs that may be eligible to participate in the Direct Loan program must, among other requirements, have verifiable completion and placement rates of at least 70%. If an IHE wants to add a new educational program to its Title IV eligibility, it generally may selfcertify to ED that the new program is Title IV eligible or, for new 300-599 clock-hour programs, submit an application to ED for approval.105 Gainful Employment (GE)106 The HEA specifies that most non-degree programs must prepare students for “gainful employment in a recognized occupation.”107 Regulations promulgated in 2014 (2014 GE regulations)108 defined the term gainful employment in a recognized occupation, but they were rescinded in 2019.109 The 2014 GE regulations were intended to serve as a proxy measure for programmatic quality by establishing debt-to-earnings (D/E) rates that programs were required to meet.110 The rationale behind the rule was that if an educational program is of sufficient quality, on Higher Education, “Accreditation review Cycle and Monitoring,” June 3, 2017, https://msche.my.salesforce.com/ sfc/p/#46000000ZDJj/a/46000000Xpre/m1fjdSZ3mx5.4hLsSR55yhFFkj5BSa6sMCGNYdgG27w. 103 In the case of single-purpose institutions (e.g., freestanding medical schools), an IHE may meet Title IV accreditation requirements if it is accredited by an ED-recognized programmatic accrediting agency. 104 34 C.F.R. §600.10. 105 34 C.F.R. §600.20; FSA Handbook, vol. 2, pp. 130-131, 134. 106 Non-degree programs offered by public, private nonprofit, and proprietary IHEs that meet the following criteria are excepted from meeting the GE requirements: preparatory coursework necessary for enrollment in a Title IV-eligible program and approved comprehensive transition and postsecondary programs for students with intellectual disabilities. In addition, teacher certification programs at public or nonprofit institutions for which the school does not award a credential are excepted from meeting the GE requirements. FSA Handbook, vol. 2, p. 25. 107 HEA §§101(b)(1), 102(b)(1), & 102(c). 108 Department of Education, “Program Integrity: Gainful Employment,” 79 Federal Register 64890, October 31, 2014. 109 The rescission is effective July 1, 2020; however, IHEs may choose to implement the rescission on or after July 1, 2019. U.S. Department of Education, “Program Integrity: Gainful Employment,” 84 Federal Register 31392, July 1, 2019. 110 U.S. Department of Education, “Program Integrity: Gainful Employment,” 79 Federal Register 64890, October 31, 2014. Congressional Research Service 27 Direct Federal Support of Individuals Pursuing Training & Education then it will lead to earnings that will enable students to repay the student loans they borrowed for enrollment in the program. Under the GE framework, each program subject to the GE rules must meet two D/E rates. Programs that fail to meet minimum standards in multiple years will be ineligible for Title IV participation for three years. No program has yet been subject to loss of Title IV eligibility under the requirements.111 In addition, the education programs subject to GE rules must meet third-party standards such as being approved by an ED-recognized accrediting agency, being recognized by the relevant state agency, being programmatically accredited (if required by a federal entity or state agency in the state in which the IHE is located or otherwise seeks state approval), and meeting any applicable educational prerequisites for professional licensure or certification in the state in which the IHE is located.112 Measures of Program Performance The HEA does not define measures of performance for the Title IV programs. The HEA does require that Title IV participating IHEs and ED report information on enrollment, certificates and degrees conferred, student charges, and other information that may be of interest to prospective and current students and policymakers.113 Program Participation ED collects data annually on Title IV non-degree instructional for-credit programs. Table 5 shows the total number of non-degree instructional for-credit programs and credentials and the percentage of non-degree instructional for-credit programs and awards by institutional sector in AY2017-2018. Of the 6,418 Title IV-participating IHEs, 4,618 offered non-degree for-credit programs. Approximately half of Title IV-eligible non-degree for-credit programs are offered by private for-profit IHEs, while more than two-thirds of non-degree for-credit credentials from Title IV-eligible programs are awarded by public IHEs.114 Table 5. Number and Percentage of Non-degree Instructional Credit Programs and Awards by Institutional Control: AY2017-2018 Grand Total Public IHEs Offering Nondegree For-Credit Programs Non-degree For-Credit Credentials Awarded 4,618 971,158 36% 69% 111 To enable ED to calculate whether an IHE’s programs meet the D/E rates, regulations specify that ED obtain data from the Social Security Administration (SSA). 34 C.F.R. §668.40(c)(1). However, a memorandum of understanding related to data sharing between ED and SSA lapsed in 2018. Thus, although programs were expected to be subject to loss of Title IV eligibility in early 2019, ED was unable to calculate D/E measures and was unable to enforce the GE rules. U.S. Department of Education, Office of Federal Student Aid, “Distribution of Final GE Completers List and Draft GE Completers Lists Correction Results,” Gainful Employment Electronic Announcement #118, April 5, 2019, https://ifap.ed.gov/eannouncements/040519GEEA118FinalCompleterListDraftCompleterListCorrectionResults.html. 112 IHEs must also disclose a variety of information regarding each of their GE programs to prospective students in their promotional materials. Information to be disclosed includes, for example, program length, program completion rates, and the total cost of each program. 113 See, for example, HEA §132. 114 CRS compiled data from the U.S. Department of Education, Integrated Postsecondary Education Data System (IPEDS), Statistical Table sum using 2017 Title IV participating institutions and 2015-2016 data. Congressional Research Service 28 Direct Federal Support of Individuals Pursuing Training & Education Private not-for-profit 14% 3% Private for-profit 50% 28% 100% 100% Percentage total Source: CRS-compiled data from the Department of Education, Integrated Postsecondary Education Data System (IPEDS), using 2018 Title IV-participating institutions and AY2017-2018 data. Notes: Non-degree credit awards are formal awards that require completion of an organized program of study at the postsecondary level (below the baccalaureate degree) involving instructional activity measured in credit hours, contact hours, clock hours, or some other unit of measurement. The program’s purpose is academic, vocational, or continuing professional education, and excludes avocational and adult basic education programs. One fairly recent report indicated that many IHEs also report non-Title IV eligible program completions to IPEDS despite IPEDS instructing IHEs to report only Title IV eligible program completions (Source: Complete College America, Certificates Count: An Analysis of Sub-baccalaureate Certificates, December 2010, p. 3, https://files.eric.ed.gov/fulltext/ED536837.pdf). Another report indicates that IHEs are not required to report certificates that require fewer than 12 credits and that are approved at the institution or regional level, but many IHEs report these data (Source: Research for Action, Research Brief: Measuring the Effects of Outcomes-Based Funding on Certificate Production: Challenges, Inconsistencies and Recommendations for Future Research, February 2019, p. 14). In AY2015-2016, approximately 765,000 Pell Grant recipients pursued non-degree credit programs and received about $2.7 billion in Pell Grant awards—roughly 10% of the total number of recipients and dollar amount of awards. Also in AY2015-2016, approximately 10% of undergraduates who borrowed a Direct Loan were pursuing certificate programs.115 Program Limitations Support for non-degree programs is limited in several ways:   Title IV aid is only available to support individuals pursuing credit programs of a statutorily specified duration at Title IV-participating IHEs. Support for work-based learning is limited to programs or portions of programs that lead to a certificate or degree and that are offered by Title IV-participating IHEs. Some students who may choose to pursue training or education via non-degree programs will not be eligible. These include    students who do not have a high school diploma (or equivalent) or who are not enrolled in a career pathway program; with respect to Pell Grants, students who have a bachelor’s degree;116 and with respect to the Direct Loan program, students enrolled less than half-time. 115 CRS analysis of U.S. Department of Education, National Center for Education Statistics, 2015-16 National Postsecondary Student Aid Study (NPSAS:16) variables UGDEG, PELLAMT, SECTOR1, and STAFFAMT; and U.S. Department of Education, Federal Pell Grant Program 2015-2016 End of Year Report, Table 18. 116 Approximately 21% of undergraduates seeking an undergraduate credit certificate in AY2015-2016 had previously earned a degree. Within two years of degree receipt, 5.8% of AY2013-2014 bachelor’s degree recipients pursued further education in a two-year institution. National Student Clearinghouse, Snapshot Report: Two-Year Enrollment after Bachelor’s Degree, Summer 2016, https://nscresearchcenter.org/snapshotreporttwoyearenrollmentafterbachelors24/. Congressional Research Service 29 Direct Federal Support of Individuals Pursuing Training & Education Non-degree program quality may vary. It is primarily assessed through the program integrity triad, since the 2014 GE rules have been rescinded. State authorizers and accreditors have some flexibility in determining and applying criteria to assess quality. Few reports have examined state authorization requirements in general, or as they relate to program quality in particular. However, those that have done so identify the variation among state authorization requirements as an impediment and a complicating factor in assessing institutional experiences with state authorization.117 They note that an individual state’s history, resources, and priorities may affect the extent to which the state chooses to take a more active or passive role in some areas, such as evaluating non-degree programs.118 Despite difficulties in assessing state authorization requirements, researchers have pointed to the following as potential weaknesses in at least some states’ authorization requirements:      concerns that the oversight of some state boards may be impaired by potential conflicts of interest, overrepresentation of special interests, or a sense of being beholden to IHEs; input requirements (e.g., faculty members’ qualifications, facilities and equipment used in the instructional process) may impede innovative education models; elongated timeframes to receive state authorization, which may be a result of a complex regulatory state process or a lack of state resources; conflicts across state laws in instances where an institution offers educational programming in multiple states; and despite the fact that many states require institutions to report on student outcomes, few states may actually make authorization renewal decisions based on those outcomes.119 A 2014 GAO report identified some of the strengths and weaknesses of the accreditation system as it relates to program quality.120 One strength is that institutional accreditors tailor their expert peer reviews depending on the school type and mission. In addition, programmatic accreditation is specifically aligned to the particular field or type of program. Potential weaknesses identified by GAO include conflicting interests between IHEs and the IHE-funded accreditors, the insufficiency of accreditor capacity and resources, the inability of exp [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3AR46306. Public record. Not legal advice.