Changes to CAMP APR

Changes to CAMP APR Presented by Nathan Weiss Office of Migrant Education 2012 HEP/CAMP Annual Directors Meeting

Outline of Presentation • Background • Overview of Key Changes • Question and Answer Time CAMP GPRA 1

Background • Some standardization is necessary to accurately compare projects and hold everyone to a consistent standard • Over the last year we have been working on revising the CAMP APR CAMP GPRA 1

GPRA 1 from APR Objective 1 of 2: All CAMP students will complete their first academic year at a postsecondary institution in good standing. Measure 1.1 of 1: The percentage of College Assistance Migrant Program (CAMP) participants completing the first year of their academic or postsecondary program. (Desired direction: increase) Calculation: This measure is calculated by dividing the number of CAMP first academic year completers (the number of CAMP eligible students who successfully completed their first academic year of college by the end of the budget period) by the total number funded, as per the approved application by OME, or the number actually served (whichever is greater), MINUS the number of persisters. CAMP GPRA 1

Full-Time Requirement for CAMP Student Eligibility • The HEP/CAMP regulations in 206.3(c)(1) require CAMP students to be, “enrolled or be admitted for enrollment as a full-time student at the participating IHE.” • 206.5(c)(4) defines full-time as, “a student who is carrying a full-time academic workload, as defined in 34 CFR part 690 (regulations for the Pell Grant Program).” CAMP GPRA 1

Full-Time (Continued) • 34 CFR part 690 goes on to reference 34 CFR 668.2(b), which defines “full-time” student as: An enrolled student who is carrying a full-time academic workload, as determined by the institution, under a standard applicable to all students enrolled in a particular educational program. The student's workload may include any combination of courses, work, research, or special studies that the institution considers sufficient to classify the student as a full-time student. However, for an undergraduate student, an institution's minimum standard must equal or exceed one of the following minimum requirements: (1) For a program that measures progress in credit hours and uses standard terms (semesters, trimesters, or quarters), 12 semester hours or 12 quarter hours per academic term. CAMP GPRA 1

Full-Time Determination • Grantees expressed concerns about how this would be applied to CAMP students • IHEs already have a standard for determining eligibility for full-time awards for PELL and other Federal Student Aid. Since we use the same definition of full-time, we will be tying into this • As such, the following explanation will appear in the verification appendix for the CAMP APR CAMP GPRA 1

Was the student enrolled at the IHE in the CAMP program with full-time status during all academic terms of the regular academic year (i.e. all terms other than summer) in which he or she was a CAMP participant? Provide an answer of “Yes” or “No” to this question. NOTE: All first academic year completers (all students listed on this page) must have been enrolled with full-time status during all academic terms of the regular academic year (i.e. all terms other than summer) in which they were CAMP participants. When making this determination of full-time status, projects should refer to their IHE’s policy for determining a student’s eligibility for a full-time PELL grant or a full-time Federal Student Aid award. If, for example, a CAMP student’s enrollment status for a given academic term would qualify him or her for a full-time PELL award at your IHE (all other eligibility requirements having been met), that student could be identified here as a full-time student in that academic term for reporting purposes [See 34CFR 206.5(c)(4), 690.2(b), and 668.2(b)]. 2012 HEP/CAMP Annual Directors Meeting

Full-Time Determination (Continued) • For most colleges, this means carrying a full-time courseload at least to a census date or the end of the add/drop period • IHEs have some flexibility on how they set the full-time standard so if you have doubts check with your registrar or financial aid office • Note that we have created an exemption for summer terms to allow summer bridge programs and making up credits in the summer if necessary CAMP GPRA 1

First Academic Year of a Program of Study: From the Regulations • In order to be eligible to participate in a CAMP, the program regulations state in 206.3(c)(2) that a student must, “Not be beyond the first academic year of a program of study at the IHE, as determined under the standards of the IHE.” • Students successfully completing the first academic year is the objective described in GPRA 1 • The determination of what constitutes the “first academic year of a program of study” is left to the IHE. • Numerous issues have arisen from the lack of consistent standards. CAMP GPRA 1

Proposed First Academic Year Standard First academic year: “First Academic Year” will be defined by the IHE in which the CAMP student is currently enrolled; however, grantees are to use the definition of an academic year in 34 CFR 668.3, which applies to the PELL program and Federal Student Aid, and which states, among other things, that a full-time student in an undergraduate educational program is expected to complete at least: 24 semester or trimester credit-hours or 36 quarter credit-hours for a program measured in credit-hours; or 900 clock-hours for a program measured in clock-hours. This minimum standard must be incorporated into the definition of an academic year. CAMP GPRA 1

First Academic Year Completer CAMP first academic year completers: The number of CAMP eligible students who complete their first academic year. The “First Academic Year” is defined by the IHE in which the CAMP student is currently enrolled, but must meet the minimum standard discussed in the definition of "First academic year", above. In addition, a student is considered to have successfully completed credit hours or clock hours if the institution considers the student to have passed the coursework associated with those hours. At a minimum then, a student cannot be considered a “first academic year completer” until he or she has passed the number of hours established in the IHE’s definition of “first academic year.” 2012 HEP/CAMP Annual Directors Meeting

Basis for First Academic Year Definitions • The regulations for PELL and Federal Student Aid in 34 CFR Part 668 currently define the minimum standards for an academic year of a program of study. • This definition is already used by these federal student financial assistance programs, in which most CAMP students likely also participate, so using this existing federal definition makes sense on several levels. CAMP GPRA 1

Minimum Standards for Academic Year of a Program of Study From 34 CFR Part 668 According to 34 CFR Part 668.3: Except as provided in paragraph (c)* of this section, an academic year for a program of study must include— (1)(i) For a program offered in credit hours, a minimum of 30 weeks of instructional time; or (ii) For a program offered in clock hours, a minimum of 26 weeks of instructional time; and (2) For an undergraduate educational program, an amount of instructional time whereby a full-time student is expected to complete at least— (i) Twenty-four semester or trimester credit hours or 36 quarter credit hours for a program measured in credit hours; or (ii) 900 clock hours for a program measured in clock hours. (*My note - Paragraph C just deals with the possibility of a waiver for a slight reduction in the length of the academic year.) CAMP GPRA 1

“First-Year Completers” Threshold: CAMP APR and 668 Regulations • The CAMP APR, on page 1, in the explanation of how to calculate GPRA 1, states that the number of CAMP first academic year completers is understood to be, “the number of CAMP eligible students who successfully completed their first academic year of college by the end of the budget period.” • 668.4 states that, “A student successfully completes credit hours or clock hours if the institution considers the student to have passed the coursework associated with those hours.” • Therefore, for a student to “successfully complete” their first academic year, they must at least pass the number of courses required in the IHE’s definition of “academic year,” with the minimum standards outlined in the previous slides. CAMP GPRA 1

Completing in Good Standing • Objective 1 on page 1 of the CAMP APR instructions states that, “All CAMP students will complete their first academic year at a postsecondary institution in good standing.” • However, the “in good standing” provision was previously included in the definition of the objective but was nullified by another statement later in the APR instructions. • We will be leaving the description of the objective the same, but will be eliminating the later statement • So, the “in good standing” requirement will now exist for first year completion. 2012 HEP/CAMP Annual Directors Meeting

Definition of “In Good Standing” from APR Instructions • “In Good Standing”: “In good standing” is defined by the IHE in which the CAMP student is currently enrolled. At a minimum, an IHE's determination that a student is in good standing means that the student is eligible to re-enroll at the IHE after having completed the first academic year. 2012 HEP/CAMP Annual Directors Meeting

Inclusion of Remedial/Developmental and ESL Coursework in Determining Enrollment Status The APR instructions state on p. 12: Additionally, in determining both a student’s enrollment level and whether or not a student is a first academic year completer, IHEs may, but are not required to, include remedial and English as a Second Language (ESL) coursework; however, an IHE's inclusion of these credits, hours, or units must be consistent with the standards in 34CFR 668.20 “Limitations on remedial coursework that is eligible for Title IV, HEA program assistance.” CAMP GPRA 1

Remedial/Developmental and ESL Coursework in 668.20 • 34CFR 668.20 contains a variety of provisions, but for our purposes it boils down to the fact that under these regulations, when determining enrollment status, IHEs can count up to one academic year’s worth of remedial courses; however, ESL classes are not subject to this time restriction. • According to 668.20, ESL classes count towards the credits considered in determining a student’s enrollment status, and: • The one-academic-year limitation that applies to other developmental/remedial classes does not apply to ESL coursework. • Unlike other remedial/developmental coursework, the ESL courses can be below what is considered to be a secondary level course. • Bottom Line: Extensive Flexibilities Exist for the Inclusion of ESL Coursework. CAMP GPRA 1

Eligibility for Enrollment- Excluding High School Courses • From pages 11-12 of the APR instructions: In determining if a student is a first-year completer, or not beyond the first academic year of a program of study at the IHE, the IHE may exclude college credits earned before the student’s graduation from high school. In other words, if a student comes into a CAMP program at an IHE on a semester academic calendar already having accrued 24 college credits in high school, that student may still be served by the CAMP program, and will be considered a first academic year completer when he or she attains at least 48 college credits. • This is based on the higher educations regulations in 668.41(a), which allows students who enter an IHE with advanced standing, defined as college credit earned before graduation from high school, to still be considered “first-time undergraduate students.” CAMP GPRA 1

Benefits ofExcluding High School Coursework? • In this way we are not be penalizing students for excelling in high school. As we know, these same students may well have other important financial and supportive services needs that would be met by the CAMP program. • For these students, completing their first year will still mean completing one year’s worth of credits, but might, for example mean going from 24-48, instead of 0-24, depending on how many college credits they earned in high school. CAMP GPRA 1

Persisters in the 5th Project Year • To compensate for the longer period of time that may be required to get a student to first year completion under more stringent definitions, we are allowing projects to count persisters in their 5th project year. • The 2011 APR stated that persisters can be counted in all years of the 5-year grant cycle (i.e., Y1-Y5). This will remain unchanged. • Only students who enroll in the next academic term after the end of the project’s 5th year could be counted as persisters. CAMP GPRA 1

Reporting Fifth Year Persisters in the Subsequent Project Period • Previously, grantees were instructed to report 5th year persisters as “new students” in the subsequent project period. • After further consideration, we have determined that this is not ideal, and have added the following language to p. 12 of the APR instructions: Those students who are counted as persisters in the 5th year’s APR will be counted as “returning students” in the Year 1 APR of the next grant. Since the students are persisters from the previous grant’s Year 5, you will not need to re-establish eligibility for those students. (See question H3 in the HEP/CAMP Eligibility Guidance.) 2012 HEP/CAMP Annual Directors Meeting

H3. Under what circumstances must a HEP or CAMP project re-establish eligibility of a student who has already been enrolled in the project and begun receiving services but has not yet finished the program? As noted in questions H1 and H2 above, once a student is enrolled in a HEP or CAMP project and begins receiving services, that student is eligible to continue receiving services until he or she has received the equivalent of a high school diploma (in the case of HEP), or completed the first academic year of a program of study at the IHE (in the case of CAMP). As long as a student has no break in services, meaning the student remained a project participant and did not leave (i.e., withdraw from) the project and re-enter, there is no need to re-establish his or her eligibility for HEP or CAMP. 2012 HEP/CAMP Annual Directors Meeting

CAMP Completers Continuing in Higher Education • New standard for continuing CAMP students. From p.13 of the CAMP APR: Continuing CAMP First Academic Year Completers: Of those students who completed their first academic year of college in this budget period, the number who continued in postsecondary education programs. To be counted as continuing in postsecondary education, the student must re-enroll in an IHE in the academic year immediately following the one in which he or she is reported as being a first academic year completer, and must remain enrolled past the date when students can no longer add courses. 2012 HEP/CAMP Annual Directors Meeting

Example of an Acceptable Definition for First-Year Completion Under the Updated Minimum Standards • The CAMP program at Anywhere State University says that CAMP students are “first-year completers” once they have reached the IHE’s published standard for Freshman year completion, which is accruing 24 credits. • This means that for a CAMP student to be considered a first year completer, he or she must complete 24 credits. Additionally, the APR definitions also require the student to be “in good standing” meaning, at least, eligible to re-enroll in the IHE. CAMP GPRA 1

Example of an Unacceptable Standard for First-Year Completion • The CAMP program at University of Nevermind states that CAMP students are “first-year completers” once they have been at the University for two semesters. In this time, students complete anywhere from zero to 24 credits. CAMP GPRA 1

A Note on FERPA • Several Directors have asked for confirmation that the information requested for GPRA verification is not a FERPA violation. • In September of 2010, the Department’s FERPA office confirmed that this disclosure to OME falls under FERPA's exception to consent as a disclosure to an "authorized representative of the Secretary" that is "in connection with an audit or evaluation of Federal or State supported education programs." (34 CFR 99.31(a)(3) and 99.35.) CAMP GPRA 1

Timeline and Next Steps • After this meeting, we will take a last chance to make edits based on any feedback we get here and the comment we got in the online tool we set up last week. • Then, the APR will go into clearance and should be finalized some time in August. CAMP GPRA 1

Questions? Nathan WeissU.S. Department of EducationOffice of Migrant Education400 Maryland Ave. SW, 3E-338Washington, DC 20202-6135202-260-7496 phone202-205-0089 faxnathan.weiss@ed.gov CAMP GPRA 1

Changes to CAMP APR