High School Equivalency Program HEP College Assistance Migrant

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High School Equivalency Program (HEP) /College Assistance Migrant Program (CAMP) Student Eligibility Steven Carr,

High School Equivalency Program (HEP) /College Assistance Migrant Program (CAMP) Student Eligibility Steven Carr, Program Officer Office of Migrant Education 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

2 Building Program Success • • Recruitment and Eligibility Services to Students Follow-up and

2 Building Program Success • • Recruitment and Eligibility Services to Students Follow-up and Placement Project Success! 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

Objectives of this Presentation • To review the basics of program eligibility. • To

Objectives of this Presentation • To review the basics of program eligibility. • To practice using the Eligibility Non. Regulatory Guidance as a resource. • To confidently make accurate eligibility determinations for HEP and CAMP. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

Organizational Overview of Eligibility LAW: Title IV, Section 418 A of the Higher Education

Organizational Overview of Eligibility LAW: Title IV, Section 418 A of the Higher Education Act of 1965 as amended by section 408 of the Higher Education Opportunity Act P. L. 110315 (H. R. 4137) • HEP 418 A(b)(1): Age, School Attendance, Work, Migrant Education Program (MEP), Workforce Investment Act (WIA), Education Status • CAMP 418 A (c)(1)(A): Work, MEP, WIA, College or University Attendance 2017 New Directors’ Orientation, August 3 rd Current Regulations: • General HEP and CAMP participation eligibility: Work, MEP, WIA • Special HEP Qualifications: Education Status, School Attendance, Age, Need • Special CAMP Qualifications: Institute of Higher Education (IHE) Admission, Not Beyond 1 st Year in IHE, Need • Program Definitions: Agricultural Activity, Farmwork, Full-time, IHE, Migrant Farmworker, Seasonal Farmworker The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families. 4

Words to Live By! 34 Code of Federal Regulations (CFR) § 206. 3 Who

Words to Live By! 34 Code of Federal Regulations (CFR) § 206. 3 Who is eligible to participate in a project? (a) General. To be eligible to participate in a HEP or CAMP project— (1) A person, or his or her immediate family member, must have spent a minimum of 75 days during the past 24 months as a migrant or seasonal farmworker; or (2) The person must have participated (with respect to HEP within the last 24 months), or be eligible to participate, in programs under 34 CFR part 200, Subpart C (Title I --Migrant Education Program) or 20 CFR part 633 (Employment and Training Administration, Department of Labor--Migrant and Seasonal Farmworker Programs). 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

6 HEP Eligibility Factors Is/Does the possible participant: A. 16 years old or beyond

6 HEP Eligibility Factors Is/Does the possible participant: A. 16 years old or beyond the state’s compulsory age? B. not enrolled in school? C. not have a high school diploma or equivalent? D. have qualifying WORK? Or have an immediate family member with qualifying WORK? E. need, as determined by the grantee, the academic and supporting services and financial assistance provided by the project to gain employment or be placed in an IHE or other postsecondary education or training? 2017 New Directors’ Orientation, August 3 rd Factor A. Age B. School Enrollment C. School Completion D. Qualifying Work E. Need The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

7 CAMP Eligibility Factors Is/Does the possible participant: A. able to be enrolled or

7 CAMP Eligibility Factors Is/Does the possible participant: A. able to be enrolled or admitted for enrollment as a full-time student at the participating IHE? B. Have at least a “qualified alien” status? C. not beyond the first academic year of a program of study at the IHE, as determined by the standards of the IHE? D. have qualifying WORK? Or have an immediate family member with qualifying WORK? E. need, as determined by the grantee, the academic and supporting services and financial assistance provided by the project in order to complete an academic program of study at the IHE? 2017 New Directors’ Orientation, August 3 rd Factor A. IHE Admission B. Status C. First-year D. Qualifying work E. Need The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

8 Components of Qualifying WORK • • • Agricultural Activity Wages/Personal Subsistence Place Duration

8 Components of Qualifying WORK • • • Agricultural Activity Wages/Personal Subsistence Place Duration (75/24) Employment q Primary q Temporary/Seasonal 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

Activity: Using the NRG as a reference • This guidance document is divided into

Activity: Using the NRG as a reference • This guidance document is divided into nine sections, labeled as letters A-I. • The sections are as follows: A. Recruitment B. Eligibility C. Determining Need D. Farmwork under 34 CFR 206. 3(a)(1) E. Temporary and Seasonal Employment F. Primary Employment G. Qualifying work under 34 CFR 206. 3(a)(2) H. Other Eligibility and Recruitment Issues I. Documenting Eligibility 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

10 Finding Example 1 Finding: For individuals qualifying under the 75 days in 24

10 Finding Example 1 Finding: For individuals qualifying under the 75 days in 24 months criterion, the project should maintain a document, such as an intake form, that clearly demonstrates the basis for the eligibility determination under this criterion. While project staff were able to demonstrate that a correct eligibility determination was made in the cases of the students whose files were reviewed at random, this had to be done by piecing together information from other parts of the file, such as the COE for a HEP student’s child, which made the basis for the eligibility determination somewhat unclear. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

11 Finding Example 2 Finding: The reviewers noted while reviewing a random sample of

11 Finding Example 2 Finding: The reviewers noted while reviewing a random sample of student eligibility forms that the descriptions of the students’ qualifying work experience were not always completely legible and were sometimes unclear. This lack of clarity appears, at least to some degree, to have come out of a lack of a full understanding of HEP participant eligibility requirements among project staff. This, in turn, may be the result of insufficient training and unclear internal policies and processes surrounding eligibility and intake. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

12 Student Example 1 Carlos, 23, dropped out of high school in the 12

12 Student Example 1 Carlos, 23, dropped out of high school in the 12 th grade. He recently moved from Michigan to Florida so he could work for wages picking in an orange grove for the harvest. Carlos would like to earn his GED. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

13 Student Example 2 A potential CAMP student’s father works at an apple farm

13 Student Example 2 A potential CAMP student’s father works at an apple farm driving a truck that takes the picked apples to the packing shed on the farm. The father’s pay stubs show he worked at the farm full-time from September –November of 2015 and plans to work again from September. November of this year. The student has been admitted to the University as a transfer from a local Community College. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

14 Group Activity The question that we have is related to potential students who

14 Group Activity The question that we have is related to potential students who drive tractors that cuts and bales hay or transports the nuts within the farm, does he qualify(? ) These students do handle the raw produce to varying degrees. For potential students who work year round, yet still meet our low income requirements via WIC from Health and Humans services. Do they qualify? 2017 New Directors’ Orientation, August 3 rd Directions 1. Analyze question using eligibility checklist. Do you have the necessary information to make an eligibility determination? 2. Use the eligibility guidance to find sections relevant to the question being asked. 3. Work within your group to develop a response that incorporates applicable sections of the guidance. o Hint: Did the director ask one question, or two separate questions? The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

15 Group Activity (continued) “I am writing to seek clarification this part of the

15 Group Activity (continued) “I am writing to seek clarification this part of the qualifying process. Reading the “GUIDANCE Recruitment and Eligibility under section 418 A of the Higher Education Act of 1965, as amended” (U. S. Department of Education Office of Elementary and Secondary Education), on page 6 -7, the following text is found: B 3. B 4. Case scenario: 19 year old client comes in to qualify for services. Client wants to qualify through Father. The client brings checks stubs from ag company. Upon review of work, dates, etc. , Father did the work at place for the amount of time and period required as per regulations. Given that, does the client need to show proof that they live together in order to qualify or do they automatically qualify because of the immediate family connection? ” 2017 New Directors’ Orientation, August 3 rd Directions 1. Analyze question using eligibility checklist. Do you have the necessary information to make an eligibility determination? 2. Use eligibility guidance to find sections relevant to the question being asked. 3. Work within your group to develop a response that incorporates applicable sections of the guidance. The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

16 Response Thank you for your question on whether a potential student could qualify

16 Response Thank you for your question on whether a potential student could qualify through their father, who you have determined meets qualifying farmwork. It is best to view (i), (ii), and (iii) of 34 CFR 206. 5(c)(5) as three separate options for qualifying for HEP through an immediate family member. In terms of immediate family, a students may qualify through: i. ii. A spouse. Or A parent, step parent, adoptive parent, foster parent, or anyone with guardianship. Or Any person who: iii. o o Claims the prospective HEP or CAMP participant as a dependent on a Federal income tax return for either of the previous two years, or Resides in the same household as the prospective HEP or CAMP participant, supports that individual financially, and is a relative of that individual. So, in this case, you would not to need to document whether they live together, but you would need to document that this student is qualifying through their father and document the father’s qualifying farmwork. I hope this helps, let me know if you have any other questions. 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

17 Resources • • HEP/CAMP Program Regulations o The code of federal regulations on

17 Resources • • HEP/CAMP Program Regulations o The code of federal regulations on the HEP and CAMP programs answers the question of who is eligible to participate in HEP and CAMP projects (34 CFR § 206. 3). To learn more about these federal regulations, visit this website: o HEP CAMP Code of Federal Regulations HEP/CAMP Non Regulatory Guidance on Student Eligibility o This website is an excellent resource on student eligibility that defines many terms related to HEP and CAMP eligibility, and also provides clarity on a variety of common eligibility questions. To learn more visit this website. o HEP CAMP Non Regulatory Guidance on Eligibility HEP/CAMP Resources o The HEPCAMP Resources webpage maintains many technical assistance presentations from the past six years. New directors may access and download the HEPCAMP Student Eligibility presentation from the 2017 Annual Directors Meeting, as well as look at other eligibility and recruiting presentations from previous years. o HEP CAMP Technical Assistance Resources HEP/CAMP Toolkit o The HEPCAMP toolkit gives an overview of recruiting for your HEP or CAMP project. o o CAMP: CAMP Recruiting Overview HEP: HEP Recruiting Overview 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.

18 Thank you! • Contact your program officer with any eligibility questions. • Steven.

18 Thank you! • Contact your program officer with any eligibility questions. • Steven. [email protected] gov • Carla. [email protected] gov • Preeti. [email protected] gov • Nathan. [email protected] gov 2017 New Directors’ Orientation, August 3 rd The mission of the Office of Migrant Education is to provide excellent leadership, technical assistance, and financial support to improve the educational opportunities and academic success of migrant children, youth, agricultural workers, fishers, and their families.