Federal Student Aid: Actions Needed to Evaluate Pell Grant Pilot for Incarcerated Students

Incarcerated students are generally prohibited from receiving Pell grants, which provide need-based federal financial aid to low-income undergraduate students. However, Education has the authority to waive specific statutory or regulatory requirements for providing federal student aid at schools approved to participate in its experiments. Accordingly, the department initiated the multi-year Second Chance Pell pilot in 2015 to test whether allowing incarcerated individuals to receive Pell grants increases their participation in higher education programs and influences their academic and life outcomes, or creates any obstacles to schools' administration of federal financial aid programs.

GAO was asked to review the Second Chance Pell pilot. This report examines (1) actions Education, schools, and other stakeholders have taken to implement the pilot; (2) experiences participating schools are having as they implement the pilot; and (3) how Education is monitoring and evaluating the pilot and whether opportunities for improvement exist.

GAO analyzed summary-level Education data from the 2016-2017 and 2017-2018 school years and interviewed a non-generalizable sample of 12 schools (and associated prison partners) that were selected for variation in type of school (i.e., public and private nonprofit), type of prisons served, and other variables. GAO also interviewed Education officials.

The Department of Education (Education) selected 64 schools across 26 states to participate in the Second Chance Pell pilot, and participating schools collaborated with prisons and other stakeholders to implement the pilot. Across the pilot's first 2 years, schools awarded approximately $35.6 million in Pell grants to about 8,800 incarcerated students.

Officials from the 12 schools GAO interviewed reported experiencing some challenges implementing the pilot. First, school officials said they experienced challenges establishing incarcerated applicants' eligibility for Pell grants, since some applicants had not registered for Selective Service and some had an existing federal student loan in default. However, many applicants were able to complete the necessary steps—such as making a set number of payments on their defaulted loans—to reestablish eligibility. Second, obtaining documents from incarcerated applicants to support verification—which helps the department's efforts to reduce improper payments of federal student aid—was another challenge officials reported. School officials also said that providing college classes in prisons required them to develop new processes and creative solutions to overcome technology limitations, space limitations, and the transfer of students to other prisons. Officials from 8 of 12 schools told GAO they hired additional staff or developed new approaches in response to their pilot efforts.

Incarcerated College Students inside New York's Sing Sing Correctional Facility

Education monitors the pilot by collecting data from participating schools, but had not established how it intended to evaluate Second Chance Pell or measure the pilot's performance against its objectives. Education is required to review and evaluate experiments under the Experimental Sites Initiative—of which Second Chance Pell is a part—and make recommendations, as appropriate, to improve the delivery of federal student aid. In its comments on the draft report, Education stated that it was planning to evaluate the pilot, consistent with the pilot's objectives, and described a number of steps it was taking to do so. Completing this evaluation can help ensure policymakers have the information needed to make decisions about the future of Pell grants for incarcerated students.

GAO recommends that the Secretary of Education complete its evaluation of the pilot to report on its findings and conclusions. Education concurred, with clarification, and stated that it had actions underway to evaluate the pilot.

The federal Pell grant program provides low-income undergraduate  students with financial aid for postsecondary education. However,  incarcerated students have been generally prohibited from receiving Pell  grants since 1994. In 2015, the Department of Education (Education)  initiated the Second Chance Pell pilot program. The pilot program allows  incarcerated students who meet all other Pell eligibility requirements to  receive Pell grants for use at selected colleges and universities. The  program has a particular focus on those students who are likely to be  released within 5 years. The objectives of the pilot are to test whether  awarding Pell grants to incarcerated students increases their participation  in higher education programs and influences their academic and life  outcomes, and to examine whether the pilot creates any challenges or  obstacles to a school’s administration of federal financial aid programs.  Education has not set an end date for the Second Chance Pell pilot, but  stated that experiments under the initiative typically run 3 to 4 years. The  pilot began its third school year in July 2018.

You asked us to review the Second Chance Pell pilot. This report  examines the following questions:  1.  What actions have Education, schools, and other stakeholders  taken to implement the Second Chance Pell pilot?  2.  What experiences are participating schools having as they  implement the Second Chance Pell pilot?  3.  How is Education monitoring and evaluating the pilot, and what  opportunities, if any, exist for improvement in these areas?

To determine what actions Education and other stakeholders have taken  to implement the pilot, we reviewed summary-level data from Education  regarding the schools and individuals that participated in the first 2 years  of the pilot. To ensure the reliability of these data, we reviewed agency  documentation about the data and the system that produced them and  interviewed officials from Education responsible for collecting and  validating the data. We found the data to be sufficiently reliable for our  purposes. To further identify the actions taken to implement the pilot, we  interviewed officials from the Department of Justice, as well as  Education’s Office of Federal Student Aid, on the actions taken to prepare  for the pilot and the guidance and support provided to participants, among  other topics. We also interviewed representatives from three research  groups—the Urban Institute, the Vera Institute of Justice (Vera), and New  America—in order to gain additional insight on the effects of  postsecondary correctional education as well as the design and  implementation of the Second Chance Pell pilot.

To understand schools’ actions and experiences implementing the pilot,  we interviewed officials from a non-generalizable sample of 12  participating schools (and associated prison partners) that were selected  for variation in type of schools (i.e. public and private nonprofit), degrees  awarded, type of prisons served, and other variables. As part of these  interviews, we also interviewed officials from seven correctional facilities  who partnered with the participating schools. We also visited three  prisons that partnered with the selected schools (Jessup Correctional  Institution in Maryland, Mission Creek Corrections Center for Women in  Washington State, and Sing Sing Correctional Facility in New York) and  one school’s campus (City University of New York) in order to observe  classrooms and student resources such as libraries and study spaces  and to talk with individuals selected by the schools about their  experiences participating in the pilot. These sites were selected for  variation in experience delivering college classes in prisons, number of  students served, and to allow us to observe both men’s and women’s  prison facilities. To further understand schools’ experiences as they  implement the pilot, we attended the third-annual convening of Second  Chance Pell partners, which was a 2-day conference for participating  schools, their correctional partners, and other stakeholders, hosted by  Vera.

To assess how Education is monitoring and evaluating the pilot, we  reviewed Education’s documentation on the pilot’s objectives (including  any evaluation objectives), analyzed the data collection instruments  Education uses to monitor the pilot, and compared Education’s efforts to  leading practices we have identified for effective pilot design and  evaluation. Our complete scope and methodology can be found in  appendix I.

We conducted this performance audit from January 2018 to March 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

First authorized in 1972, the Pell Grant Program awards federally-funded  grants to low-income undergraduate and certain post-baccalaureate  students who are enrolled in a degree or certificate program (which can  include vocational programs) and have federally-defined financial need.  Education’s Office of Federal Student Aid administers the Pell Grant  program and other federal student aid programs—grants, loans, and  work-study—authorized under Title IV of the Higher Education Act of  1965, as amended. Students are eligible to receive Pell grants for no  more than 12 semesters (or the equivalent). The maximum allowable Pell  grant for the 2018-2019 school year was $6,095.

The amount a student receives is based on a formula that compares the  estimated cost to attend a particular school with a student’s expected  family contribution toward that cost. A student’s expected family  contribution is determined by considering his or her income and assets, or  for students who are dependent or independent students who are  married, their income and assets as well as that of their parents or  spouses. Students are eligible for federal need-based aid if their cost of  attending a school is more than their expected family contribution.  Students incarcerated in federal or state penal institutions have been  ineligible for Pell grants since the enactment of the Violent Crime Control  and Law Enforcement Act of 1994. Beginning in the 2016-2017 school  year, the Second Chance Pell pilot has allowed a limited number of  students to receive Pell grants despite their incarceration.

In general, to be eligible to receive federal student aid (including Pell  grants), Department of Education guidance states that an applicant must: be a citizen or eligible noncitizen of the United States; have a valid Social Security Number; have a high school diploma or a General Education Development  certificate, or have completed homeschooling; be enrolled in an eligible program as a regular student seeking a maintain satisfactory academic progress; not owe a refund on a federal student grant or be in default on a  federal student loan;  register (or already be registered) with the Selective Service System,  if the person is a male and not currently on active duty in the U.S.  Armed Forces; and not have a conviction for the possession or sale of illegal drugs for an  offense that occurred while the person was receiving federal student  aid (such as grants, work-study, or loans).

For the Pell grant program, an applicant must also demonstrate financial  need and not have obtained a bachelor’s degree or a first professional  degree.

In the 2016-2017 school year, more than 18.6 million prospective  students applied for federal student aid by submitting the Free Application  for Federal Student Aid (FAFSA). The FAFSA consists of more than 100  questions that collect information ranging from basic contact information  to the current value of assets. Several questions ask for financial  information, which could require applicants (and their parents and  spouses, if they are dependent or married) to rely upon information  located on tax returns, as well as information from bank, business, and  investment records. Incarcerated individuals in the Second Chance Pell  pilot are required to apply for financial aid using the same process as  students in the non-incarcerated population.

After Education processes an applicant’s FAFSA, a report is sent to the  applicant or made available online. This report includes the applicant’s  expected family contribution, the types of federal aid for which the  applicant qualifies, and information about any errors—such as questions  the applicant did not complete—that Education identified during FAFSA  processing. Schools send applicants award letters after admission,  providing students with types and amounts of federal, state, and  institutional aid, should the student decide to enroll.

Education uses a process called “verification” to help identify and correct  erroneous or missing information in students’ FAFSAs, which helps the  department’s efforts to reduce improper payments of federal student aid.

Education selects approximately 30 percent of FAFSAs for verification  each academic year and schools are required to work with the selected  students to confirm the accuracy of the information provided on their  FAFSAs. A student is responsible for gathering the necessary  documentation—such as prior years’ tax returns or proof of having  obtained a high school diploma—and providing it to the school financial  aid office, which compares the information submitted in the FAFSA to the  student’s supporting documentation. If there is a difference between the  student’s documentation and what he or she submitted on the FAFSA,  the FAFSA information may need to be corrected.

When selecting FAFSAs for verification, Education aims to select those  FAFSAs with the highest statistical probability of error and the impact of  such error on award amounts. Education’s specific criteria for selecting  FAFSAs for verification is not public information; however, the department  periodically refines its process for selecting FAFSAs to reduce the burden  of verification on applicants, their families, and schools while maintaining  the integrity of the federal student aid programs.

Education publishes a list of potential verification items for each award  year in the Federal Register. The items that schools are required to  verify for a given application are selected by Education from that list. For  the 2018-2019 school year, the items for verification are shown below:

Untaxed portions of Individual Retirement Arrangement distributions,

Untaxed portions of pensions,  Individual Retirement Arrangement deductions and payments,

Tax-exempt interest income,  Income earned from work,

Education credits, and  Identity and statement of educational purpose.

Research on the Effects of Participating in Education while Incarcerated

The body of literature on prisoners’ participation in educational programs  while incarcerated suggests there may be benefits for participants, the  facilities in which they are housed, and taxpayers. However, positive  benefits attributed to postsecondary correctional education are not always  clear because the students who would have done better post-release may  have been more willing or motivated to participate in the program anyway.  See appendix II for a summary of selected research on correctional  education. See appendix III for additional information on the educational  attainment of the prison population.

Education, Participating Schools, and Other Stakeholders Took Several Actions to Implement the Second Chance Pell Pilot

Education Selected 64 Schools to Participate in the Second Chance Pell Pilot

In response to an August 2015 Federal Register notice announcing the  pilot, Education officials reported receiving applications from over 200  schools seeking to participate. The officials said they selected schools  for the pilot that varied along several characteristics, including location  and size, as well as ensuring that selected schools did not have a history  of compliance issues or other problems delivering federal student aid.  Education selected 64 schools to participate in the pilot and officially  notified schools in June of 2016 that Pell-funded courses could begin as  early as July 1 of that year. The 64 schools are located across 26 states  and include public and private nonprofit 2- and 4-year schools. Figure 1  below shows the locations and numbers of the 64 schools selected to  participate in the pilot and figure 2 includes additional information on 3  schools participating in the pilot that were included our sample. Appendix  IV includes a complete list of the schools Education selected to  participate in the pilot and select characteristics of those schools.

Education, Schools, Prisons, and Others Collaborated to Prepare for and Implement the Pilot

To prepare for the pilot, Education took a number of actions. For  example, Education hosted four webinars for officials at schools selected  to participate in the pilot. The first two webinars occurred in September  2015, during which Education officials discussed the pilot’s objectives and  strategies for establishing effective partnerships between schools and  prisons. The third webinar took place in July 2016 and covered how to  navigate the federal financial aid application process and the information  Education planned to collect from schools, among other topics. Education  held the final webinar in August 2016 in collaboration with the Department  of Justice. The webinar contained information on how schools and their  prison partners could develop shared goals, roles, expectations, policies,  and procedures, and how these might be incorporated into a  memorandum of understanding. Education also developed a Frequently  Asked Questions page on its website and responded to questions  submitted by school officials via email. In addition, Education hosted  breakout sessions for Second Chance Pell schools at its annual Federal  Student Aid Training Conference in 2016, 2017, and 2018.

School officials reported working with a variety of stakeholders to prepare  for and to implement the pilot. For instance, officials from 7 of 12 schools  we interviewed said they collaborated with one or more additional  stakeholders within the school, such as individuals working in academic  departments, financial aid, the registrar, the bursar, and academic  advising. For example, officials from one school said administrators  partnered with the bursar and the registrar to ensure that incarcerated  students were not unenrolled from classes if their Pell grants took longer  to be disbursed than those for non-incarcerated students. Officials from  10 of 12 schools we interviewed talked about the importance of  coordinating with staff at the prison, and officials from 9 schools said  coordinating with their states’ departments of corrections was important  for implementing the pilot. For example, officials from one school said  their state Department of Corrections demolished a wall at one  participating prison in order to provide more classroom and study space  for the program.

Finally, schools described collaborating with organizations that help  facilitate college courses in prisons. For example, officials from all 12  schools we interviewed said that Vera provided technical assistance, such as information-sharing and opportunities to network with other pilot  schools. Officials from one school also noted that they partner with  Hudson Link, an organization that recruits students for postsecondary  correctional education programs and supports students’ reentry upon  release, among other activities.

Almost 8,800 Incarcerated Students Received a Pell Grant in the Pilot’s First 2 Years

Across the pilot’s first 2 years, 59 Second Chance Pell schools disbursed  approximately $35.6 million in Pell grants to a total of 8,769 individual  students. See table 1 for a comparison between the first and second  school years.

Not all of the 64 schools selected for the pilot began offering Pell-funded  classes at the start of year one. Specifically, 11 of the 64 selected schools  were unable to offer classes in the pilot’s first year and 5 of the 64  selected schools did not offer classes in the second year. Education  officials told us that some schools needed additional time to stand up their  programs, as the department allowed, for a number of reasons. For  example, officials said:

Some schools with new correctional education programs faced delays  obtaining accreditation for those programs.

Some schools needed additional time to work out operational details,  such as obtaining credentials or security clearances in order for  faculty and staff to enter the prison.

Some schools needed additional time to build relationships with  correctional partners.

Figure 3 shows incarcerated students taking college classes inside two  New York prisons.

Officials from Selected Schools Reported Experiencing Some Challenges Implementing the Pilot, but Developed New Approaches to Address these Challenges

School Officials Reported Challenges in a Few Areas Required to Establish Incarcerated Applicants’ Eligibility for Pell Grants

School officials we interviewed said that they experienced some  challenges establishing incarcerated applicants’ eligibility for aid,  including establishing an applicant’s citizenship or eligible non-citizenship  and providing accurate Social Security Numbers or Alien Registration  Numbers. For example, officials from 6 of the 12 schools we interviewed  said that some of their incarcerated applicants did not know or have  access to their Social Security Number. The two most commonly- identified reasons applicants were initially ineligible for Pell grants were  (1) some applicants had not registered for Selective Service, and (2)  some had an existing federal student loan in default status. Schools and  applicants faced challenges addressing these reasons.

Selective Service. Generally, to be eligible to receive Pell grants,  applicable male students must have registered with the Selective  Service. However, for male students who have not registered,  institutions may determine that the student is not ineligible for a Pell grant  if the student can demonstrate by submitting evidence to the institution  that (1) he was unable to present himself for registration because of  reasons beyond his control—such as hospitalization, incarceration, or  institutionalization—or (2) he is over 26 and when he was between the  ages of 18 to 26, he did not knowingly and willfully fail to register with the  Selective Service.

Education data showed that about 15 percent of the FAFSAs submitted in  the pilot’s first year were from applicants who had not registered for  Selective Service. In comparison, 2 percent of FAFSAs in the overall  population were submitted by applicants who had not registered. School  officials said that many applicants had been continuously incarcerated  between ages 18 to 26, but that obtaining documentation to demonstrate  this was difficult in some circumstances. For example, officials from one  school reported that obtaining records from juvenile correctional facilities  was challenging and officials at another school said that applicants did  not always know or have access to their exact dates of incarceration.

Men over age 26 who had not been continuously incarcerated but who  wished to apply for federal financial aid must obtain an official response  from the Selective Service System confirming that the individual did not  register, but should not be denied federal benefits. To obtain this official  response, the student can write or call the Selective Service System with  a detailed description of the circumstances he believed prevented him  from registering at the required time. The individual would then provide  the official written response from the Selective Service System to his  school financial aid office, which would evaluate whether his failure to  register was knowing or willful. Officials from 7 of the 12 schools we  interviewed said the process to obtain documentation from the Selective  Service System was difficult or time-consuming.

Student Loan Default. Applicants are generally ineligible for Pell grants if  they have a prior federal student loan in default status. Education data  showed that about 10 percent of FAFSAs in the first year of the pilot were submitted by applicants with an existing federal student loan in default  status. In comparison, about 2 percent of FAFSAs in the overall  population were submitted by applicants with an existing loan in default  status. Officials from all 12 schools we interviewed said at least some of  their incarcerated applicants had existing federal student loans in default  status. There are options, however, for individuals to remove default  status from their loans, potentially regaining eligibility for Pell grants. For  example, borrowers may rehabilitate their student loans by entering into  and completing a written agreement that requires the borrower to make  nine on-time monthly payments within 10 consecutive months. These  income-driven payments can be as low as $5 per month.

According to school officials, however, removing default status from loans  can be challenging for incarcerated individuals. For example, officials  from one school we interviewed said applicants generally cannot make  phone calls to set up loan repayment plans and instead have to rely on  postal mail for completing the necessary paperwork. Also, officials from  another school we interviewed said that for applicants who must rely on  family members outside the prison to make the required payments, there  is no guarantee that the family will do so. Additionally, borrowers may  rehabilitate a loan only once. Despite these challenges, officials from  five schools said they had applicants who were working to rehabilitate  their loans, such as by paying from wages earned through prison work or  by having family members make payments on their behalf. Officials from  two of those schools said they had one or more applicants who  successfully rehabilitated their loans and were able to enroll in the pilot.

School Officials Reported Challenges Verifying Incarcerated Applicants’ Income and Assets

According to school officials we interviewed, verifying incarcerated  applicants’ income and assets was challenging, in particular, because of  circumstances unique to applicants being in prison. Communication  between the applicant, the applicant’s family, and the school’s financial  aid office is limited by virtue of the applicant’s confinement. For example,  incarcerated applicants were typically unable to be reached via phone or  email to answer questions, according to school officials we interviewed,  and completing verification paperwork sometimes required multiple trips  to the prison, which in some cases was more than an hour away. Further,  incarcerated applicants sometimes did not have access to their personal  files or records and faced difficulties obtaining documentation, such as  copies of high school transcripts and tax records, which may be required  for financial aid officers in the event the applicant is chosen for  verification. Education guidance indicates that under certain  circumstances, the school may accept alternate forms of documentation  from the correctional facility if that documentation provides the information  the school has requested. For example, the school may accept  documentation from the correctional facility that shows an individual was  incarcerated for the entire corresponding tax year, rather than requiring  the applicant to obtain a letter of non-filing from the Internal Revenue  Service.

School officials said that some dependent and married students had  trouble providing the school financial aid office with income  documentation for others, such as a parent or spouse. According to  Education data, approximately 2 percent of incarcerated applicants in the  first year of the pilot were dependent, and nearly 11 percent were  married. If an applicant selected for verification is dependent or married,  he or she is required to provide the school with documentation to verify  household income. Officials from 7 of the 12 schools we interviewed said  that sometimes an applicant had trouble securing required documents  from a parent or spouse. If an applicant cannot provide the required  documentation of the income and assets of his parent or spouse, the  school cannot verify the individual’s FAFSA information and cannot award  a Pell grant.

School officials indicated that these challenges were compounded by the  selection of a high percentage of Second Chance Pell FAFSAs for  verification. Education uses a number of criteria to select FAFSAs for  verification, which the department does not share publicly. However,  Education officials said that being eligible for a Pell grant and reporting no  income are two such criteria. As a result, schools that serve more Pell- eligible applicants are likely to have more of their applicants’ FAFSAs  selected for verification than schools that serve fewer Pell-eligible  applicants. Accordingly, 76 percent and 59 percent of pilot FAFSAs  were selected for verification in the 2016-2017 and 2017-2018 school  years, respectively. Education’s verification selection rate for non- incarcerated, Pell-eligible applicants was 53 percent in the 2017-2018  school year. Figure 4 below shows Education’s verification selection rates  for non-incarcerated Pell-eligible applicants and incarcerated applicants in  these first two school years.

Schools Hired Staff and Developed New Approaches to Address Challenges

Officials from 8 of the 12 schools we interviewed reported hiring additional  staff or allocating more staff hours to help manage the increased  administrative workload. For example,

Officials from one school said their school added six full-time  employees to process financial aid for their pilot students.

A financial aid officer from another school stated that her workload  has increased since the pilot began, and she has taken on additional  tasks, such as training other staff to fill in when she could not travel to  the prison.

Officials from another school said they have added positions in the  academic, administrative, and financial aid departments to handle the  additional administrative workload.

In addition, officials from 9 of 12 schools said they developed new  approaches to address challenges related to processing FAFSAs  submitted by incarcerated applicants. For example:

Start Early: Officials from one school reported collecting FAFSAs  earlier in the second year than they had in the first year to allow for  additional time to collect documentation for applicants who may be  selected for verification. An incarcerated student we spoke with  echoed this challenge when he spoke of difficulties locating prior  years’ tax returns. See sidebar for additional experiences shared by  incarcerated students we met with. Officials from two schools reported  having applicants complete verification-related paperwork, such as  requests for supporting documentation from federal entities like the  Internal Revenue Service, at the same time they completed their  FAFSA. The officials said this approach reduced the number of visits  the officials had to make to the prison and helped school officials and  incarcerated applicants keep track of the required paperwork.

Pre-screen Applicants: Officials from two schools reported pre- screening their incarcerated applicants for common issues that affect  financial aid eligibility so that they could work with applicants to begin  to correct these issues (such as helping applicants learn how to make  payments to rehabilitate loan default status). Other schools used pre- screening to reduce the school’s workload, since they were able to  exclude ineligible applicants before they submitted a FAFSA.

Track and Report on Status: Officials from one school said their  information technology department developed a system that  generates a report on the documentation that incarcerated applicants  have provided and the documentation that remains outstanding. The  report also contains notes from staff members on their document  requests with the Selective Service System, Internal Revenue  Service, and other agencies.

Officials from Selected Schools Reported Logistical Challenges in Providing Prison-based Classes, but Many Schools Developed New Approaches to Address Them

School officials we interviewed reported that providing college courses in  prisons required them to develop new processes and generate creative  solutions to help overcome technology limitations, space limitations, and  the transfer of students to other prisons, among other limitations. For  example, officials from 9 of the 12 schools said that limited technology in  prisons, especially limited access to the Internet, presented a challenge.  An official from one school said that classroom discussions were  enhanced by the low-technology setting. To overcome technology  limitations, officials from one school said that it partnered with the state  libraries to develop a solution to deliver research materials to students.  Specifically, an incarcerated student mails a research request to a state  library. Once received, a librarian will locate the requested articles and  electronically send the material to the prison’s secure printer. A prison  staff member will then deliver the material to the student. default status and could not access a  prior year’s tax return, making the process  take longer.

Officials from 9 of the 12 schools we interviewed said that space and  scheduling limitations in prisons also presented a challenge. School  officials told us they must compete for classroom space with other  programming that is offered—or in some cases required by law, such as  GED education—to inmates. Officials from two schools said they hold  night and weekend classes to address such limitations. Officials from one  school also reported that prison staff changed incarcerated students’  schedules (such as meal times and other scheduled activities) to  accommodate their academic needs. Additionally, some prison officials  reported relocating all the student inmates into the same housing unit to  help create a positive learning environment. helps inmates be less idle and therefore  less likely to engage in negative behavior.  elevates the status of students in the  prison, and the younger people look up to  him and his college-going peers.

Officials from 7 of the 12 schools we interviewed said at least one  incarcerated student was either transferred to another prison or was  released during the pilot. To address the issue of students being  transferred to a different prison, officials from three schools said they  developed an agreement with their state’s department of corrections that  students participating in the pilot would not be transferred to other  facilities until the end of the academic term. and open a nonprofit organization serving  youth.

December 2018. He plans to work toward  becoming a home inspector and attend  classes at the main campus, where he  has applied for an academic scholarship.  released by the end of 2018, was proud to  be leaving prison with a college degree.  He plans to start a business and mentor  young men to pursue education.  year sentence. He plans to start a  business upon release and had  developed a business plan as part of his  studies. He also plans to work with at-risk  young men to steer them away from crime  and towards education.

To monitor Pell dollars spent and other aspects of the pilot, Education  systematically collects data from participating schools. Education requires  schools to report data monthly, to complete an annual report, and to  respond to a survey each academic year. Education officials said they  use schools’ monthly reporting—which is limited to the participating  students’ Social Security Numbers and last names—to monitor Pell grant  disbursements. Education requires schools to report annually on the  students who completed FAFSAs, including the number of credits that  students attempted and earned and the dollar amount students were  assessed for tuition and fees, for example. Education officials reported  that they will follow up with schools that are not reporting data to  determine if the school either has no data to report or needs further  assistance from the department.

As part of its annual survey to schools, Education asks officials to  describe any challenges their schools faced when implementing the pilot,  such as the roles and responsibilities of schools and corrections partners  for helping incarcerated applicants complete FAFSAs, as well as how  academic programs were determined. In addition, Education asks schools  to share examples of any challenges their schools faced when  implementing the pilot. Education sent its first annual survey to Second  Chance Pell schools in August 2018, in which it asked school officials to  reflect on the pilot’s first year (2016-2017 school year). Education officials  reported that all schools had completed the required reporting for the first  year of the pilot (2016-2017) and that as of November 2018, 47 schools  had completed their reporting for the second year of the pilot (2017- 2018). Specific data elements collected by Education for the pilot are  presented in appendix V.

Education Has Not Yet Evaluated Pilot Results

A key component of the Experimental Sites Initiative—of which Second  Chance Pell is a part—is rigorous evaluation of whether experiments  achieve their stated objectives. Education is directed to review and  evaluate the experiences of schools participating in its experimental sites  and report biennially on the findings and conclusions reached regarding  each of the experiments conducted. Further, the department is directed  to make recommendations for amendments to improve and streamline  the Higher Education Act, which includes the delivery of federal student  financial aid, based on the results of the experiments. However,  Education has not established how it intends to evaluate Second Chance  Pell or measure the pilot’s performance against its objectives.

During the course of our review, Education officials provided us with  several reasons as to why they were not planning to evaluate the pilot.  First, officials said there was no dedicated funding set aside for an  external evaluation of the pilot. Second, Education officials said they did  not intend to make recommendations regarding changes to federal  student financial aid eligibility based on the results of the pilot. Rather  than conducting an evaluation, they explained, Education intends to  report descriptive information on the pilot, such as the number of students  served and the amount of aid disbursed, as it has done in prior reports on  its experimental sites. In Education’s most recent report on the  experimental sites (of the 2010-2011 school year), the department  reported that it aggregated outcome measures (such as numbers of  students in each experiment) and reviewed comments submitted by  participating schools. However, the report noted that this type of  anecdotal information could not be used to determine whether  experiments were ultimately successful.

The purpose of a pilot is generally to inform a decision on whether and  how to implement a new approach in a broader setting. In this context,  leading practices for effective pilot design state that agencies should  evaluate the final results of a pilot in order to draw conclusions on  whether, how, and when to integrate pilot activities into overall efforts.  As noted above, Education is required to review and evaluate  experiments under the Experimental Sites Initiative and make subsequent  recommendations, as appropriate, for amendments to improve and  streamline the Higher Education Act, which includes the delivery of  federal student financial aid. In this context, we inquired about steps  Education could take now, should an evaluation of Second Chance Pell  be pursued (including an evaluation limited to an internal effort using  existing resources). Education officials agreed that even without funding  for an external evaluation, they could use the data they are already  collecting to internally evaluate the pilot. In its comments on the draft  report, Education stated that it was now planning to evaluate the pilot,  consistent with the objectives set out in the Federal Register, and  described a number of steps it was taking to do so. We are pleased to  see the Department taking these important steps to determining the pilot’s  impact. An evaluation of Second Chance Pell can help provide  policymakers with the information needed to make decisions about the  future of Pell grants for incarcerated students.

Pell grants help open the door to a college education for millions of low- income students every school year. However, over the past 24 years,  incarcerated students have been generally ineligible for Pell grants.  Education’s Second Chance Pell pilot presents an opportunity for policy  makers and others to see whether participation in postsecondary  educational opportunities increases when Pell grants are again made available, and to determine what impacts a college education has on an  incarcerated person’s academic and life outcomes. These impacts may  be consistent with past research, which suggests possible benefits to  formerly-incarcerated individuals, prisons, and local communities. Second  Chance Pell, by the end of its second year of implementation, has  allowed thousands of incarcerated students to receive financial aid for  college. Evaluating the pilot can help assure Education and Congress  have the information needed to make decisions about the future of Pell  grants for incarcerated students.

We are making the following recommendation to Education:

The Secretary of Education should complete its evaluation of Second  Chance Pell in order to report on the pilot’s findings and conclusions  reached.

We provided a copy of this report to Education and DOJ for review and  comment.  Education provided written comments, which are reproduced  in full in appendix VI. DOJ did not provide written comments.

Regarding our recommendation to evaluate Second Chance Pell and  report on its findings, Education concurred, with clarification. Education  stated that it is already taking a number of actions to evaluate the pilot,  including gathering information from participating schools and other  sources. Education also stated that it will be analyzing the data it is  collecting to report on the pilot’s objectives. Education, accordingly,  suggested the recommendation should be worded that the Department  “continue to” evaluate Second Chance Pell. We describe Education’s  data collection efforts in our report; however, at the time of our review  Education was not able to provide evidence that it was evaluating the pilot  and stated on more than one occasion that it planned to report descriptive  information about the pilot’s outcomes (such as the amount of Pell dollars  disbursed), because it did not have funding for an evaluation. We are  pleased to see that the Department is now planning to evaluate the pilot  and report on the pilot’s objectives, and accordingly, we revised our report  and recommendation to state that Education should complete its  evaluation. An evaluation of Second Chance Pell that goes beyond  summarizing descriptive information can help provide policymakers with  the information needed to make decisions about the future of Pell grants  for incarcerated students.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  appropriate congressional committees, the Secretary of Education,  Attorney General, and other interested parties. In addition, the report is  available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-8777 or goodwing@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff members that made key  contributions to this report are listed in appendix VII.

To identify the actions Education and other stakeholders took to  implement the Second Chance Pell pilot, we reviewed summary-level  data from the Department of Education (Education) regarding the first two  years of the pilot—school years 2016-2017 and 2017-2018—on the  schools that participated in the pilot, the number of incarcerated  individuals who applied for and received Pell grants, and other aspects of  the pilot. To ensure the reliability of these data, we reviewed agency  documentation about the data and the system that produced them and  interviewed officials from Education responsible for collecting and  validating the data. We found the data to be sufficiently reliable for our  purposes. To further identify the actions taken, we reviewed Education’s  published guidance on implementing the Second Chance Pell pilot,  including the department’s webinars, action plans, and Frequently Asked  Questions document. Additionally, we interviewed officials from the  Department of Justice, as well as Education’s Office of Federal Student  Aid, on the actions taken to prepare for the pilot and the guidance and  support provided to participants, among other topics. We also interviewed  representatives from three research groups—the Urban Institute, the Vera  Institute of Justice (Vera), and New America—in order to gain additional  insight on the effects of postsecondary correctional education as well as  the design and implementation of the Second Chance Pell pilot.

To further identify what actions schools and correctional facilities took to  implement the pilot, we interviewed officials from a non-generalizable  sample of 12 schools participating in the pilot. We also interviewed  officials from seven correctional facilities who partnered with the  participating schools. We used a sampling procedure in which we  selected participating schools with particular characteristics to capture  both common experiences and important variations among those with  differing characteristics. We selected schools to represent a range of  characteristics, including public and private nonprofit schools; schools  with existing postsecondary correctional education programs and those  with programs launched for the pilot; and schools with a varying number  of correctional institution partners (ranging from 1 to 18 partners). We  selected schools that offered bachelor’s degrees to students participating  in the pilot as well as those that offered certificates and associate’s  degrees. We included one school serving a women’s prison, one school  that is classified as one of the Historically Black Colleges and  Universities, and four schools that are classified as Hispanic Serving  Institutions in our sample. Results from nonprobability samples cannot be  used to make inferences about a population. Although our findings cannot  be generalized to all schools that are participating in the pilot, they do  provide useful insight into the experiences of pilot participants.

To describe the experiences that participating schools are having as they  implement the Second Chance Pell pilot, we interviewed officials from the  non-generalizable sample of schools (and correctional partners) we  described above. Additionally, we visited three prisons (Jessup  Correctional Institution in Maryland, Mission Creek Corrections Center for  Women in Washington State, and Sing Sing Correctional Facility in New  York) and one school campus (City University of New York) in order to  observe classrooms and student resources such as libraries and study  spaces and to talk with selected individuals about their experiences  participating in the pilot. Specifically, one of the prisons for men that we  visited identified five Second Chance Pell students for us to interview.  Each interview was conducted in a private classroom setting with one  student and two of our staff members. Each interview lasted between 5  and 10 minutes. Each student was asked the same set of questions about  his experience applying for and participating in the Second Chance Pell  Pilot Program. Although these interviews were only conducted at one site  and are therefore not generalizable to all students participating in the pilot  program, they provide insight about the students’ experiences. We also  observed a pilot-funded class in session at that prison. On one college  campus, we interviewed a student who participated in the pilot while he  was incarcerated and who was now released and continuing his  education on campus. These sites were selected for variation in  experience delivering college classes in prisons, number of students  served, and to allow us to observe both men’s and women’s prison  facilities. To further understand schools’ experiences as they implement  the pilot, in June 2018 we attended the third-annual convening of Second  Chance Pell partners, which was a 2-day conference for participating  schools, their correctional partners, and other stakeholders, hosted by  Vera.

To assess how Education is monitoring and evaluating the pilot, and what  opportunities, if any, exist for improvement, we reviewed Education’s  documentation on the pilot’s objectives (including any evaluation  objectives), and analyzed the data collection instruments Education uses  to monitor the pilot. We met with Office of Federal Student Aid officials to  discuss the department’s plans for evaluating and reporting on the pilot’s  results. We compared Education’s efforts to leading practices we  identified for effective pilot design and evaluation. We interviewed officials  knowledgeable in the area of evaluation and prison education, including  officials from the Urban Institute, Vera, the Washington State Board of  Community and Technical Colleges, and New America. Finally, we asked  officials from our purposive sample of schools about their experiences  with Education’s reporting requirements, perspectives on what additional  information Education could collect to demonstrate the outcomes of the  pilot, and how schools themselves were measuring the performance of  their programs apart from what they were reporting to Education.

Appendix II: Research on the Effects of Participating in Education while Incarcerated

Our Method to Select Research Literature

To determine what is known about the effects of participation in  postsecondary correctional education, we conducted a literature search  for studies that analyzed the relationship between inmate participation in  postsecondary educational programs while incarcerated and outcomes  both while in prison and after release. Our literature search identified 221  published studies for review using a three-stage process. We:  (1)  Searched 16 authoritative bibliographic databases such as SCOPUS,  ERIC, PsychINFO, and ProQuest’s Dissertations and Theses  Professional using relevant search terms, such as “postsecondary  correctional education,” “postsecondary education,” and “prison,”  (2)  Identified citations in the studies detailed above that appeared  germane to our research interests and did not already appear in our  list of studies, and  (3)  Identified several organizations with subject matter expertise, based  on mentions in the studies detailed above and organizations identified  in our prior work. We consulted the website of each organization for  any studies on the effects of correctional education.

To assess each study’s methodological rigor, we obtained information  about each study’s methodology. We based our assessments on  generally accepted social science standards. We eliminated studies that  met any of the following criteria: (1) published prior to 2000; (2)  considered the education level of inmates, rather than participating in  education while incarcerated; (3) did not include postsecondary  educational programs; (4) did not use appropriate statistical methods to  adjust, or control, for group differences; or (5) involved a comparison  group that was not applicable to our research interests, such as juveniles.  In the first stage of the review, we examined the study abstracts.  Following the first stage of the review, 42 studies remained. In the second  stage, we read the full description of the study’s methodology. Following  the second stage, 20 studies remained for our in-depth review.

Based on our review of the literature described above, studies found that  inmates who participated in a correctional education program while  incarcerated generally achieved more positive outcomes after release  (e.g. higher employment, lower recidivism) than inmates who did not  participate in a correctional education program while incarcerated. In  2013, RAND Corporation published a meta-analysis of 58 studies and  found that inmates who participated in correctional education had 43  percent lower odds of recidivating than non-participants, and 13 percent  higher odds of obtaining employment. Many studies we reviewed that  tested impacts on one or more measures of recidivism have also found  that incarcerated students who participated in a postsecondary program  or earned a postsecondary degree while in prison were less likely to be  re-arrested or re-incarcerated than those who did not participate. Some  research, however, has found that program completion may lead to  positive effects more than participation alone. For example, in one study,  researchers found completion of a postsecondary program while in prison  was associated with significantly and substantively lower odds of  returning to prison for either a new crime or a parole violation, but  participation in a postsecondary program without completion offered no  benefit relative to not having participated at all. Additionally, not all  researchers have observed positive effects in all study settings. In one  three-state study, researchers found that those who participated in a correctional education program were less likely to be re-arrested, re- convicted, and re-incarcerated in two states; in the third state, there were  no significant differences between participants and non-participants.

Additionally, some research suggests incarcerated students who  participated in a postsecondary program while in prison were more likely  to find employment after release, work more hours, or earn higher wages  than those who did not participate, but this was not always found. For  example, in one study, earning a postsecondary credential while  incarcerated was associated with an increase in total hours worked and  total wages earned in the first 2 years after release; however, it was not  associated with an increase in the odds of finding employment.  Additionally, one study of inmates in three states found no statistically  significant difference in post-release employment in the 3-year follow-up  among participants in a correctional education program compared to non- participants.

Several studies found that correctional education had positive outcomes  for taxpayers due to lower re-incarceration costs. For example, the RAND  Corporation estimated that for every dollar spent on correctional  education, five dollars are saved on three-year re-incarceration costs.  Another cost analysis in Washington State found that correctional  education had a return-on-investment of $19.62 for participants and  taxpayers for each dollar spent, and vocational education in prison had a  return-on-investment of $13.21 for each dollar spent.

A few studies focused on outcomes for participants while they were still in  prison, and these generally suggest positive effects. For example, one  qualitative study found that participants in a postsecondary correctional  education program reported experiencing increased self-esteem and  motivation to reach their goals. A few other studies suggested that  participation in education programming reduced misconduct. In one  study, participants in college programs (but not other education  programs) reported receiving fewer tickets for misconduct. A 2006  meta-analysis, however, found that participating in an educational or  vocational program was not as effective at reducing misconduct as were  other types of programming.

The research we identified on correctional education has several  limitations. First, the identified studies often measure dependent and  independent variables in a variety of ways, which makes comparison of  outcomes across studies difficult. For example, some studies define  “recidivism” as rearrest within 3 years, while others measure it as re- arrest or reincarceration within 1 year. Another example is that many  studies define “participation in education” as participation in a vocational,  secondary, or postsecondary program, while others define it as  participation specifically in a postsecondary program. Second, of the  studies we reviewed all but one include a small, geographically limited, or  otherwise non-generalizable sample. Third, many of the studies we  reviewed do not examine whether and how characteristics of facilities or  implementation procedures may have influenced—negatively or  positively—outcomes among participants. We identified nine articles that  specifically discuss implementation and facility characteristics; however,  none employ robust methodologies to test whether and how these  characteristics lead to better outcomes among participants. A fourth  limitation is selection bias, which is the possibility that incarcerated  students who choose to take classes are meaningfully different from  those who choose not to enroll, and that difference is the underlying  cause of their positive outcomes. For example, it is possible that  incarcerated people who take educational classes are already at the  lowest risk of recidivating and have the highest motivation to succeed  after release. If this is the case, then lower rates of recidivism and higher  rates of employment may be an effect of these characteristics rather than  an effect of taking classes while incarcerated. While some of the studies  we reviewed took methodological steps to reduce selection bias, not all  did.

Appendix III: Select Characteristics and Educational Attainment Levels of the Incarcerated Population

The United States had an estimated 6.6 million prisoners under the  jurisdiction of state and federal correctional authorities as of December  31, 2016 (year-end), according to the Bureau of Justice Statistics.  According to an analysis of 2009 American Community Survey data,  Black, Hispanic, and other non-white individuals make up about 32  percent of the total household population but are about 64 percent of the  male prison population. Further, 23 percent of incarcerated men had  received some postsecondary education, compared to about 56 percent  of men in the household (non-incarcerated) population as shown below in  figure 5.

Among the incarcerated population, the analysis also found differences in  educational attainment by race. Specifically, for men age 18-24, about 10  percent of black men and about 11 percent of Hispanic men had  completed at least some college, compared to about 17 percent of white  (non-Hispanic) men.

The educational characteristics of incarcerated women were similar to  that of men. Specifically, incarcerated women have lower levels of  educational attainment compared to women living in households;  however, incarcerated women had overall higher levels of educational  attainment compared to incarcerated men. Fifty-eight percent of women  in the household population had some postsecondary education  compared to about 31 percent of incarcerated women, as shown below in  figure 6.

Appendix IV: Selected Characteristics of Schools Education Selected to Participate in the Second Chance Pell Pilot

Table 2. Selected Characteristics of Schools Education Selected to Participate in the Second Chance Pell Pilot

Appendix V: Data Items Collected by the Department of Education for the Second Chance Pell Pilot

Appendix VI: Comments from the Department of Education

Appendix VII: GAO Contact and Staff Acknowledgments

In addition to the contact name above, Melissa Emrey-Arras (Director),  Brett Fallavollita (Assistant Director), Charlotte Gamble (Analyst in  Charge), Sarah Williamson, Marissa Jones Friedman, Billy Commons,  Elizabeth Dretsch, Eric Hauswirth, Debra Prescott, Kevin Reeves, and  Ben Sinoff made key contributions to this report.

Federal Pell grants help open the door to a college education for millions of low-income students every year. However, students in prison are generally ineligible for the grants.

The Department of Education is experimenting with changing that in its Second Chance Pell pilot. Since 2015, 59 schools participating in the pilot have awarded about $35 million in Pell grants to about 8,000 incarcerated students.

The department collects data from participating schools but hasn't determined how to evaluate the pilot—which could help decide the future of Pell grants for students in prison. We recommended evaluating and reporting on the pilot.