Substantive Change: Pell-Eligible Prison Education Programs
Prior HLC approval or notification may be required when an institution offers a new Pell-eligible prison education program (also referred to as PEP) or changes the modality of a previously approved PEP. See HLC’s Glossary for the definition of a PEP and other related terms, including oversight entity, correctional facility and best interest determination.
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Federal PEP Requirements
See the Federal Student Aid Knowledge Center: Prison Education Programs for federal expectations and requirements for PEPs. Prior to seeking approval from HLC for a new PEP, institutions are required to obtain approval from the relevant oversight entity for the correctional facility.
Revised Second Chance Pell Experimental Sites Initiative
Institutions currently participating in the U.S. Department of Education’s Revised Second Chance Pell Experimental Sites Initiative (ESI) remain responsible for seeking HLC approval no later than the expiration of the timeframe for such ESI (three award years), if they intend to continue offering Pell-eligible prison education programs.
PEP Resources
Webinar on HLC’s Policies and Processes
Watch our recorded webinar on the Pell-eligible prison education program (PEP) process. It covers HLC’s PEP policy, substantive change application, screening form and stipulations, as well as our additional location confirmation visits for PEP.
Guidebook on Prison Higher Education Programs
HLC collaborated with the Vera Institute of Justice on a guidebook for accreditors and their peer reviewers, providing insight into the unique context and goals of postsecondary education in correctional facilities.
Screening Form
After an institution receives HLC approval for its first PEP, it should use HLC’s screening form to report the following changes:
- New PEP(s) started at an approved PEP location.
- New PEP(s) started at a third or subsequent PEP location. (Note: HLC approval is required for offering programs at an institution’s first two PEP locations. Please complete HLC’s PEP application.)
- The introduction of a modality that differs from all the modalities HLC previously approved for any of the institution’s PEPs, regardless of location or program.
Types of Requests
New Programs
Change to Program Modality
Follow-Up Reviews
Additional Location Confirmation Visit for PEPs
Additional location confirmation visits for PEPs are conducted for an institution’s first two approved PEPs at two separate correctional facilities. The review takes place within six months of the matriculation of students who are incarcerated and initiation of instruction at each correctional facility.
Best Interest Determination
Two years after an institution is approved by the U.S. Department of Education to offer its first PEP at a correctional facility, the oversight entity for the correctional facility, in collaboration with the institution, must conduct an initial best interest determination. See the U.S. Department of Education’s requirements related to the best interest determination.
For Oversight Entities: Collaboration With HLC Regarding Methodology
As part of the best interest determination process, the accreditor provides input to the oversight entity regarding the methodology that the oversight entity will use to determine that the PEP meets the same standards as substantially similar programs at the institution that are not PEPs and otherwise meets related federal requirements.
If an oversight entity would like to collaborate with HLC regarding its proposed methodology, a representative of the oversight entity should complete the Oversight Entity Best Interest Determination Form. HLC will review and respond.
For Institutions: Notifications to HLC
If, as the result of the best interest determination, an oversight entity determines that an institution’s PEP is not in the best interest of the students, or otherwise reaches any negative finding related to the PEP, the institution must inform HLC by emailing [email protected] and attaching a copy of the best interest determination with its findings. HLC will review and may then request additional follow-up information as needed.
Related Resources
