Especially in the areas affecting Upward Bound, program performance (APR) and the next grant...

Especially in the areas affecting Upward Bound, Especially in the areas affecting Upward Bound, program performance (APR) and the next grant program performance (APR) and the next grant

competition.competition.

Dave FergusonDave Ferguson559-276-3778559-276-3778

[email protected]@csuchico.edu

An Introduction to the Higher Education An Introduction to the Higher Education Opportunity Act (HEOA)Opportunity Act (HEOA)

Objectives

• Familiarize you with HEOA and possible new UB regulations

• Familiarize you with process of finalizing new regulations

• Involvement: Commenting, planning programs and changes, and preparing for the next grant competition

HEOA: Large TRIO Impact

• HEOA became law Aug. 14, 2008• It is a massive 432 page law.

– 5 years late and after an unprecedented 14 extensions of the statutory deadline.

– It was last reauthorized in 1998– It reflects the “current” educational

philosophy of Congress

A Review of the Law

• HEOA is the authorizing legislation for ALLALL federally funded higher education programs– It has 11 titles or subsections– The U.S. Dept. of Education MUSTMUST create

or amend regulations to interpret the law.

The 11 Subsections of HEOA

• Title 1: General Provisions• Title 2: Teacher Quality Enhancement• Title 3: Institutional Aid• Title 4: Student Assistance

– Includes financial aid and TRIOTRIO• Title 5: Developing Institutions• Title 6: International Education Programs

The 11 Subsections of HEOA

• Title 7: Graduate and Postsecondary Improvement Programs

• Title 8: Additional Programs• Title 9: Amendments to Other Laws• Title 10: Private Student Loan Improvement• Title 11: Studies and Reports

The Structure of Title IV of the Law• TITLE IV—STUDENT ASSISTANCE• PART A—GRANTS TO STUDENTS IN ATTENDANCE AT

INSTITUTIONS OF HIGHER EDUCATION• Sec. 401. Federal Pell Grants. • Sec. 402. Academic competitiveness grants. • Sec. 403. Federal TRIO ProgramsSec. 403. Federal TRIO Programs. • Sec. 404. Gaining early awareness and readiness for

undergraduate programs. • Sec. 405. Academic Achievement Incentive Scholarships. • Sec. 406. Federal Supplemental Educational Opportunity Grants. • Sec. 407. Leveraging Educational Assistance Partnership

program. • Sec. 408. Special programs for students whose families are

engaged in migrant and seasonal farm work. • Sec. 409. Robert C. Byrd Honors Scholarship Program. • Sec. 410. Child care access means parents in school. • Sec. 411. Learning Anytime Anywhere Partnerships. • Sec. 412. TEACH Grants.

The Structure of HEOA

• § or Sec. 403. FEDERAL TRIO PROGRAMS• (a,b,c)• (1,2,3)• (A,B,C)• (i,ii,iii)• (I,II,III)• (aa,bb,cc)

HEOA Themes for all TRIO• Rigorous secondary school program of

study• Participants with high risks for academic

failure – LEP– Homeless and foster youth– Disconnect youth– New classifications of veterans

Changes in UB Services

• Permissible service now REQUIREDREQUIRED– Tutoring– Secondary & postsecondary course

selection– Preparing for college entrance exams– Completing college applications– Financial aid information

Changes in UB Services

• Permissible service now REQUIRED (cont)REQUIRED (cont)– Assistance in the following:

• Secondary school reentry• Alternative education for dropouts• Entry in GED programs• Financial/economic literacy for

participants & parents

Implementation Process

• Negotiated Rulemaking– For program specific regulations– Grant applications

• Notice of Proposed Rulemaking• Regulation published for public comment• Publish regulations

UB Community’s Duties• Educate colleagues and stay informed• Be alert for draft regulations for comment• Analyze impact on program, target schools,

and institution• Plan and start testing new programs NOWNOW• Begin gather Need data• Assert needs

Make public comments!Make public comments!

In Anticipation of Change

HEOA Definitions

• §645.6 (b) provide definitions the examples– Financial/economic literacy examples:Financial/economic literacy examples:

• Personal/family budget planning• Understanding credit building

principles to meet long/short-term goals

• Cost planning for ps education

HEOA Definitions

• §645.6 (b) provide definitions the examples – Financial/economic literacy Financial/economic literacy examples examples

(continued):(continued):• PS cost of attendance• Scholarships, grants & loans education• FASFA assistance

HEOA Definitions• §645.6 (b) provide definitions the examples:

– Foster care youth• Youth in foster care; those who left after

age 13 and those aged out of foster care– Homeless children(§725 McKinney Vento

Homeless Assistance Act)• Means individuals who lack a fixed,

regular, and adequate nighttime residence


– Disconnected youthDisconnected youth• Not in school• Not working• Lacking a strong social networks that

provides assistance

Note: Note: Above is not regulation but a GAO definition. NRM did not recommend a definition so it would be

left up the programs.

Note: Note: Above is not regulation but a GAO definition. NRM did not recommend a definition so it would be

left up the programs.

HEOA Definitions

• §645.6 (b) provide definitions the examples:– VeteranVeteran

• Served 180 days, discharged under conditions other than dishonorable

• Discharged because of service disability• A reservist call to active duty for more

than 30 days• A reservist called to duty after 9/11/01.


– Regular secondary school diplomaRegular secondary school diploma• Meets or exceeds state high school

requirements– Individual with disabilitiesIndividual with disabilities

• A person with diagnosed physical or mental impairment that substantially limits ability to participate in TRIO educational experiences and opportunities


– Rigorous high school Rigorous high school program of study program of study (determined by 34 CFR 691.16):(determined by 34 CFR 691.16):

– Program which students complete minimum: • 4 years of English• 3 years of math: algebra I and higher

levels such as geometry, data analysis & statistics

• 3 years of science with 1 years each of biology, chemistry and physics

HEOA Definitions

• §645.6 (b) provide definitions the examples:– Rigorous high school program of study Rigorous high school program of study

(determined by 34 CFR 691.16):(determined by 34 CFR 691.16):– Program which students complete

minimum (continued): • 3 years of social studies• 1 year of a language other than English


– Rigorous high school program of study Rigorous high school program of study (determined by 34 CFR 691.16):(determined by 34 CFR 691.16):• Advance Placement, honors and/or

International Baccalaureate programs• A school identified by the state with a

partnership with State Scholars Initiative of the Western Interstate Commission for Higher Education (WICHE)


– High risk for academic failure High risk for academic failure (regular participant)• Has not achieved proficiency in state

reading, language arts or math• Has not completed pre-algebra, algebra

or geometry• G.P.A. less than 2.5 (4.0 scale) for the

most recent school year


– High risk for academic failure High risk for academic failure (veteran)• Has been out of high school or

dropped out of a postsecondary education for 5 or more years; or

• Has scored on standardized tests below the level needed for admission to a program of postsecondary education.

Required Services

Can anyone remember Can anyone remember what we’re all about?what we’re all about?

Required Services• §645.11 What services do all Upward

Bound projects provide?– Academic tutoring: Academic tutoring: secondary or ps

courses, which may include• Reading and writing• Study skills• Math and science• Other subjects

Required Services

• §645.11 What services do all Upward Bound projects provide?– Advice and assistance in secondary & ps Advice and assistance in secondary & ps

course selection.course selection.– College entrance exam & application prepCollege entrance exam & application prep– Financial aid and scholarship info & Financial aid and scholarship info &

assistanceassistance

Required Services• §645.11 What services do all Upward

Bound projects provide?– Guidance & assistance hs reentry; Guidance & assistance hs reentry;

alternative hs for dropouts; GED alternative hs for dropouts; GED programs; and ps programsprograms; and ps programs

– Financial/economical literacy for students Financial/economical literacy for students & parents& parents

Required Services

• §645.11 What services do all Upward Bound projects provide?– Core curriculum Core curriculum (maintained)

• Math through pre-calculus• Lab sciences• Foreign language• Composition and Literature

Required Services

• In addition to the above services in §645.11, Veteran UBsVeteran UBs must also include the following service:– Special services, including math and

science preparation, to enable veterans to make the transition to postsecondary education.

Optional Services

Optional Services

• §645.12 What services may Upward Bound projects provide?– Cultural events, academic programs &

other programs unavailable to disadvantaged

– Career info, activities and instruction– Residential programs

Optional Services

• §645.12 What services may Upward Bound projects provide?– Mentoring– Work-study – Special services for veterans– All of the required services (§645.11) but

with LEP emphasis

Selection of Participants

Current Regs Governing Selection• §645.3 Who is eligible to participate in a UB

project?– Citizen or national of US– Permanent resident or evidence of

becoming permanent– Potential first-generation– Low-income

Current Regs Governing Selection• §645.3 Who is eligible to participate in a UB

project? (continued)– Completed 8th grade but not entered 12th– At least 13 years old and not older than 19– Meets definition of veteran and other

selection criteria except age limitations– A veteran who served more than 180 days,

any part of which occurred after 1/31/55.

Current Regs Governing Selection

• §645.3 Who is eligible to participate in a UB project? (continued)– Has a need for academic support in order

to pursue successfully a program of education beyond high school

Current Regs Governing Selection

• §645.4 Requirements of first-generation and low-income:– 2/3 eligible participants must be both

low-income & first-generation– 1/3 eligible participants can be either

low-income or first-generation

HEOA Eligibility Changes

• §402A (c) (2) (B) PARTICIPANT NEED– In making grants…the Sec. shall consider

the number, percentage & needs of eligible participants in the area…

Reinforces the NEEDS basis of TRIO programs.Reinforces the NEEDS basis of TRIO programs.

HEOA Eligibility Changes

• §403A (e) (3) Documentation of status as a low-income individual– Notwithstanding this subsection…

individuals who are foster care youth…or homeless children, shall be eligible to participate…

Accommodation for new classifications of participants.

Accommodation for new classifications of participants.

Determining low-income

• Unchanged documentation requirement)– Signed statement– Verification of governmental source– Signed financial aid application– Tax return

Determining Eligibility• New foster/homeless criteria

– Foster status as determined by court– Homeless as determined by McKinney-

Vento Homeless Assistance Act

Determining Eligibility• Documenting homelessness

– Living in a motel, trailer part or campground

– Living in emergency or transitional shelters– Abandoned in a hospital– Awaiting foster placement– Sharing the housing of other persons due

to loss of housing or economic hard

Determining Eligibility• Documenting homelessness (continued)

– Having a primary nighttime residence that is a private or public place not designed for or ordinarily used for sleeping

– Living in living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings

– Migrants

Determining Eligibility• Documenting homelessness (continued)

– Not in the physical custody of a parent or guardian

NOTE: Documentation requirements have not been established in regulation yet as there has been no recommendation from the Negotiated Rule Making Committee. The homeless documentation here are “best guesses” based on the McKinney-Vento Homeless Assistance Act.

NOTE: Documentation requirements have not been established in regulation yet as there has been no recommendation from the Negotiated Rule Making Committee. The homeless documentation here are “best guesses” based on the McKinney-Vento Homeless Assistance Act.

HEOA Program Assurances

• 2/3 eligible participants must be low-income and first-generation oror students who have a high risk for academic failure. (changechange)

• Remaining participants be low-income or first-generation. (unchangedunchanged)

HEOA Program Assurances• Eligible participants have a need for

academic support. (no changeno change)

• Eligible participants have completed the 8th grade, at least 13 years old but not more than 19 years old. (changechange)

Possible Eligibility Challenges• Determining objective percentages for

grant application/competition• Documenting eligibility• Retaining high risk participants• Improving g.p.a. and test scores• Insuring high risk participants are ready for

college

Prior Experience

Prior Experience Defined

• §402A (c) (2) PRIOR EXPERIENCE…. the Secretary shall consider each applicant’s prior experience of service delivery under the particular program for which funds are sought.

• Congress’s way of rewarding programs that fulfill their objectives with continuous funding.

Prior Experience NOW• §645.32 How does the Secretary evaluate

prior experience?– (a) … the Secretary reviews info relating

to an applicant's performance under its expiring UB grant including info derived from annual performance reports, audit reports, site visit reports, project evaluation reports, & any other verifiable info submitted by the applicant.

Prior Experience NOW

• §645.32 How does the Secretary evaluate prior experience?– (b) The Secretary evaluates the

applicant's prior experience in delivering services on the basis of the following criteria:

5 criteria worth 3 points each = 15 points5 criteria worth 3 points each = 15 points

Prior Experience NOW• §645.32 How does the Secretary evaluate prior

experience?– (1) (3 pts) Whether the applicant serves the

number of participants agreed to under the approved application;

– (2) (3 pts) The extent to which project participants have demonstrated improvement in academic skills & competencies as measured by standardized achievement tests & g.p.a.;

Prior Experience NOW• §645.32 How does the Secretary evaluate prior

experience?– (3) (3 pts) The extent to which project

participants continue to participate in the Upward Bound Program until they complete their secondary education program;

– (4) (3 pts) The extent to which participants who complete the project, or were scheduled to complete the project, undertake programs of postsecondary education; and

Prior Experience NOW• §645.32 How does the Secretary evaluate

prior experience?– (5) (3 pts) The extent to which

participants who complete the project, or were scheduled to complete the project, succeed in education beyond high school, including the extent to which they graduate from postsecondary education program

Proposed PE Language• (1) (3 pts) Whether the applicant provided

services to the number of participants required to be served under the approved application;

• (2) (1pt) The extent to which the applicant met or exceeded the percentage in its objective relating to improvement participants’ skills as measured by g.p.a;

Different format; different point system.Different format; different point system.

Proposed PE Language

• (3) (2 pts) The extent to which the applicant met or exceeded the percentage in its objective relating to improvement in participants; skills as measured by tests required by the students’ State, or in instances in which no State test is required beyond the tenth grade, other standardized tests;

Proposed PE Language• (4) (2 pts) The extent to which the

applicant met or exceeded the percentage in its objective relating to participants’ continued secondary school enrollment;

• (5) (2 pts) The extent to which the applicant met or exceeded the percentage in its objective relating to participants’ completion of secondary school by entering cohort;

Proposed PE Language• (6)(2 pts) The extent to which the applicant

met or exceeded the percentage in its objective related to completion of a rigorous curriculum;

• (7)(2 pts) The extent to which the applicant met or exceeded the percentage in its objective related to postsecondary enrollment; and

Proposed PE Language

• (8) (1pt) The extent to which the applicant met or exceeded the percentage in its objective related to college enrollment through the third semester.

NOTE:NOTE: Though there are 88 requirements proposed, Prior Experience still has a maximum of 1515 pts.

NOTE:NOTE: Though there are 88 requirements proposed, Prior Experience still has a maximum of 1515 pts.

Plan to Earn Maximum PE

• Staff should start planning NOWNOW for how they will meet all of the proposed PE criteria.

• Research to determine objectives’ percentage standards.

• Concentrate on the Plan of Evaluation and the Plan of Operation.

• Staff should start planning NOWNOW for how they will meet all of the proposed PE criteria.

• Research to determine objectives’ percentage standards.

• Concentrate on the Plan of Evaluation and the Plan of Operation.


• Application Evaluation Plan– Standards to be met for each PE criteria– How will they be measured?– Formative evaluation processes– Timeline that include benchmarks

Don’t wait until Nov. APR to learn you haven’t met your objectives!

Don’t wait until Nov. APR to learn you haven’t met your objectives!

Plan to Earn Maximum PE• Application Plan of Operation

– (2) The plan for identifying, recruiting, and selecting participants to be served by the project;

– (5) The curriculum, services and activities that are planned for participants in both the academic year and summer components;

Plan to Earn Maximum PE• Application Plan of Operation

– (9) The plan to work cooperatively with parents and key administrative, teaching, and counseling personnel at the target schools to achieve project objectives; and

– (10) A follow-up plan for tracking graduates of Upward Bound as they enter and continue in postsecondary education.

Plan to Earn Maximum PE• The plan for identifying, recruiting, and selecting

participants:– PercentagePercentage of “high risk” participants– MethodsMethods for identifying “high risk” participants

• The curriculum, services & activities for participants in the academic & summer components– How will staff accommodate the needsaccommodate the needs of

participants with a wider range of abilities and skills?


• The plan to work cooperatively with parents & key administrative, teaching, & counseling personnel at the target schools to achieve project objectives– What differentdifferent connections, networks,

communication methods, participant contacts, etc. are needed


• A follow-up plan for tracking graduates of UB as they enter & continue in postsecondary education– Are differentdifferent tracking methods needed

for “high risk” participants?– How will UB graduates be supportedbe supported

after leaving the program?

Conclusion• HEOA is a monumental shift for UB.• Programs must adapt or die.• Once regulations are finalized and grants

approved, there will be no more business as usual.

• Programs must systematically plan for changes.

• Work needs to begin NOWNOW to accommodate the new regulations.

Upward Bound’s Bright Future

• Let’s stay in touch• Share your public comments• Demand chapter and WESTOP leadership

accommodate discussion and support• Check in to the University of Washington

TRIO Training website for updates

http://uw.trio.orghttp://uw.trio.org

Especially in the areas affecting Upward Bound, program performance (APR) and the next grant...

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