60D Comment Response Summary

Upward Bound and Upward Bound Math Science Programs - Annual Performance Report Summary of Public Comments with Responses

Introduction

The U.S. Department of Education received two comments from individuals interested in the Upward Bound (UB) and Upward Bound Math Science (UBMS) Annual Performance Report (APR) which addressed several topics. The comments centered around several areas of concern, which included: the new subsection on target schools, a new definition of schools served by UB and UBMS projects, the definition of postsecondary credential, accreditation requirements, and participation in Federal Student Aid Programs.

New Subsection on Target Schools

Comments: The Department received two comments on our intention to add to the APR a subsection (Section I, Part 4) on UB and UBMS projects’ target schools—that is, schools designated by a grantee as a focus of project services, as defined in our regulations (CFR 645.6). Using this subsection, TRIO seeks to gather information that will provide potential participants and the public with more up-to-date and accurate information on these schools than we currently possess. One commenter thought, however, that data collected via this subsection would be incomplete and repetitive. Having alluded to projects that are focused primarily on target areas (also defined in CFR 645.6), another commenter suggested that references to target schools be changed to “target area schools” or “schools in designated target areas.”

Response: There are limitations to the Department’s current data on target schools. First, our existing school data is sometimes out of date: schools listed in the funded proposals’ profile sheets may no longer be participating, may have changed name or NCES number, or may have been consolidated with another school. The current data field in the UB-UBMS APR on participants’ schools specifically asks for the school the student attended at time of entry into the project; the school may or may not have met the definition of a target school, and in later years the participant may have left the school. While projects are required to obtain TRIO’s approval to add or discontinue a given target school relationship, the Department needs to use the most efficient and accurate means to consolidate this new information; we believe that adopting this subsection would provide that means.

The Department declines to propose a new definition for schools that UB-UBMS projects serve. The commenter’s suggestion appeared to be based on the idea that projects focus either on a geographic target area or on target schools; our regulations do not establish such a dichotomy. Even if a project is more focused on its target area than on target schools, the project should still determine whether to designate a given school as a “focus of project services”; if the school cannot be said to meet that definition, then its students are to be counted in the line in Section I, Part 4, that asks for the number of participants who did not attend a target school at all during the reporting period.

Changes: None.

Definition of Postsecondary Credential or Certificate

Comment: The Department received one comment requesting clarification of the definition of postsecondary credential or certificate.

Response: In Final Regulations for the Federal TRIO Programs published October 26, 2010, the Department discussed acceptable credentials for the Upward Bound (UB) and Upward Bound Math Science (UBMS) postsecondary completion objective in 34 CFR 645.31(b)(1)(vi). Consistent with the definition of an institution of higher education in the authorizing statute, the Department commented that it considers a program of postsecondary education to be combination of courses and activities whose curriculum is designed to lead to the attainment of an associates or bachelor’s degree. Postsecondary certificates, vocational and adult education programs are not to be considered in the measurement of the UB and UBMS postsecondary completion objective.

Changes: None.

Accreditation Requirement

Comment: One comment asked if institutions of higher education that award postsecondary credentials used for the measurement of the UB and UBMS postsecondary completion objective must be accredited.

Response: The Higher Education Act of 1965, as amended, (20 USC section 1001), cites the General Definition of an Institution of Higher Education for Title IV (Federal TRIO) Programs. Among the requirements in the HEA is the requirement that an institution of higher education provide an educational program for which the institution awards a bachelor’s degree or provides not less than a two-year program that is acceptable for full credit toward such a degree, or awards a degree that is acceptable for admission to a graduate or professional degree program, subject to review and approval by the Secretary. Section 1001 of the HEA also states that an institution of higher education is accredited by a nationally recognized accrediting agency or association, or if not so accredited, is an institution that has been granted pre-accreditation status by such an agency or association that has been recognized by the Secretary for the granting of pre-accreditation status, and the Secretary has determined that there is satisfactory assurance that the institution will meet the accreditation standards of such an agency or association within a reasonable time.

Changes: None

Federal Student Aid Participation

Comment: One comment asked if an institution of higher education awarding postsecondary credentials must be listed in the FSA School Code Directory.

Response: Institutions of higher education are listed in the Federal Student Aid (FSA) School Code Directory when they have met the requirements for awarding of student financial aid under the Federal Student Aid Programs. There is no requirement in the UB and UBMS statute or program regulations that an institution of higher education be listed in the FSA School Code Directory in order to award an associate or bachelor’s degree that is acceptable for the measurement of the postsecondary completion objective.

Changes: None