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Integrated Pell Grant Expansion and Bachelor’s Completion Pay for Performance:
A Cost-Effectiveness Analysis
Harrison G. Holcomb
William T. Drier
School of Public Affairs
University of Colorado – Denver
Author’s Note: The authors wish to thank Todd Ely Ph.D. Assistant Professor, Jane Hansberry
Ph.D. Scholar-in-Residence, Benoy Jacob, Ph.D. Assistant Professor, Paul Teske, Ph.D. Dean,
and Amanda Buchanan, MPA Candidate, for providing us with their invaluable assistance. Our
participation in this competition is sponsored by the School of Public Affairs at UC-Denver.
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Executive Summary Improving both overall bachelor’s degree completion rates and equity in those completion rates
between low-income citizens and others should be a policy priority for the United States at the
national level. The slow growth in the credential completion rate and the gap in bachelor’s degree
completion between the wealthiest and poorest Americans threatens both economic growth and
the strength of democratic principles in government. This memo evaluates the cost effectiveness
of implementing two integrated policy solutions that focus on improving equity in educational
attainment as a way to boost bachelor’s degree completion in the United States. The first is an
expansion of the existing Pell Grant program to cover the costs of concurrent enrollment programs
for low-income high school students. Participation in concurrent enrollment has been shown to
considerably increase the probability of both attending university and obtaining a degree. The
second is the launch of a voluntary pay for performance initiative for four-year institutions to
incentivize closing the current degree completion gap between low-income students and their
better off peers. These initiatives are designed to work in tandem to improve educational
attainment for low-income students from all backgrounds. We project that in the ten year period
between 2017 and 2027, these policy solutions can generate a total of up to 2.3 million new
bachelor’s degrees for a total cost of about $3.45 billion. The rationale of our approach is
summarized in the logic model presented in Figure 1 below:
Figure 1: Integrated Pell Expansion and Pay for Performance Theory of Change Logic Model
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Understanding the Challenge of Degree Completion
The target population: low income students
Low-income students comprise a large and increasing portion of both secondary and
postsecondary students in the United States. The Department of Education reports that the
percentage of secondary students who qualify for free or reduced price school lunch, a common
proxy for poverty, increased from about 38% in 2001 to 51% in 2013.1 Similarly, the percentage
of students qualifying for Pell grants, which are based on family or individual income, have held
steady at about 60% of applicants for federal financial aid.2 Also, the number of students reporting
family incomes below $30,000 has increased.3 This low-income population often faces multiple
barriers to success in postsecondary education, including a higher probability of being first-
generation students, members of disadvantaged minority groups, or dependent care
responsibilities. Low-income students also vary in age, with adult learners more common in this
population.4 Research in this population has also indicated higher levels of sensitivity to the costs
of higher education, meaning that the presence or absence of financial aid, and how that aid is
packaged have a disproportionate impact on their decision-making for further education.5,6
The impact of underachievement
As a result of these barriers, low-income students complete postsecondary education at much lower
rates than their better off peers. The Pell Institute reported that in 2015, while 77% of dependent
students in the top income quintile for the United States completed a bachelor's degree within six
years, only 9% of students in the bottom income quintile hit the same benchmark.7 The Education
Trust indicates that at all levels of academic promise, and across all institutional types, students
who receive Pell Grants perform worse than their better off peers.8 Since students fitting the low-
income profile represent a significant portion of current and future postsecondary students, this
inequity in completion rates has a significant negative impact on overall completion rates.
Impacts on society
This poor postsecondary completion rate and its disproportionate impact on low-income students
has a negative impact on U.S. economic growth, weakens democratic participation, and can be
associated with poorer population health outcomes. Higher levels of education among workers are
associated with higher wages and greater worker productivity, leading to increased rates of
economic growth.9,10 Further, low levels of education reduce income for those workers, negatively
impacting both the equity and efficiency of the economy. A general level of equity in educational
attainment is also important to maintaining democratic principles of governance, since an ability
to both access and interpret information about issues facing the state is essential for all citizens.11
Citizens with considerably lower levels of educational attainment will be less able to engage in
this core democratic activity, meaning disparities in education lead to disparities in democratic
participation.
The importance of the bachelor’s degree credential
There are a variety of first level postsecondary credentials available to students, including technical
certificates, associate’s degrees, or a bachelor’s degrees. Since the problem is rooted in concerns
about democratic participation and economic equity and efficiency, it makes sense to target the
bachelor’s credential as it is associated with the strongest increases in earnings potential.12,13
4
Thus, increasing this credential could reasonably be expected to have the most long-term impact
on improving equity.
Concurrent Enrollment: A Proven Strategy to Improve Educational Outcomes
Concurrent enrollment programs, which allow high school students to take college courses jointly
with high school classes, have been widely implemented across the United States, with all 50 states
documenting some concurrent enrollment programs operating at the local level.14 47 states have
also established state level policies and guidelines. These programs take a variety of forms.
However, the predominant model, used by more than 60% of programs, allows high school
students to take college-level courses taught by college faculty either on campus or at their high
school.15 Participation in concurrent enrollment has been associated with a variety of benefits for
students including: increased high school graduation rates, higher rates of enrollment in
postsecondary education, higher postsecondary graduation rates, and reduced time to degree.16
One analysis conducted on students in the University of Texas system found that participants in
concurrent enrollment graduated from college at a rate of 65%, and at a median time of 4.15
years.17 Another study, conducted at Boise State University also found positive outcomes for
students that participated in concurrent enrollment programs including improved academic
performance.18
However, despite widespread implementation, participation in concurrent enrollment remains
comparatively low, particularly among low-income students. The US Department of Education
reports that in 2013 only 8% of US students participated in concurrent enrollment with local
universities.19 Further, in the state of Colorado, low-income students (defined as those receiving
free or reduced price lunch) were considerably underrepresented, participating at about half the
rate of their better off peers.20 These low participation rates and disparities in participation mean
that the potential benefits of concurrent enrollment programs are not being realized.
One reason for this underuse of concurrent enrollment is the lack of guaranteed funding for tuition,
fees, textbooks, and transportation required of participants. Particularly to those who are more
sensitive to educational costs than higher income peers, as noted by both Heller and St. John.21,22
Only 15 states provide any state-level funding for concurrent enrollment programs, with others
leaving it to the discretion of local school districts to fund.23 Among the states that do provide any
funding, even fewer cover all costs or target low-income students. This results in more limited
program implementation and presents a barrier to low income students.
Filling the Concurrent Enrollment Funding Gap: Pell Expansion Program The Pell Grant program was launched for the 1973-4 academic year, with the purpose of providing
financial support to low-income students pursuing postsecondary education. The program is
administered by the Department of Education, under authority granted to the department by the
Higher Education Act.24 In order to be eligible for a Pell Grant under the current system, a student
must be enrolled at least part time at postsecondary school eligible to receive federal aid and
complete a Free Application for Federal Student Aid to demonstrate financial need.25 Pell grants
are made on a sliding scale, based on the student’s ability to pay, number of credits attempted, and
the expected educational costs.26 Under current policy, students participating in concurrent
enrollment programs are not eligible to receive Pell grants or any other form of federal financial
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aid to cover costs. This is despite the fact that most students participating in concurrent enrollment
programs are at schools that meet the institutional eligibility criteria for Pell, specifically the rule
that the coursework must count toward some academic program that can lead to a credential,
including a bachelor or associate degree.27
Our proposal would expand the Pell Grant program to include high school seniors participating
in concurrent enrollment programs at institutions eligible to receive federal aid dollars. The
requirement to complete a FAFSA to demonstrate need and document enrollment would remain
the same, however students would be entitled to up to one academic year of additional eligibility
for concurrent enrollment which would not be counted toward the six years of postsecondary
eligibility that students are currently granted.
Other aspects of the program, including award calculation procedures and funding allocations for
administration by colleges and universities would remain largely unchanged. The only difference
being that concurrent enrollment students would be treated as full time enrollees for the purposes
of award calculation. Pell grants are subject to the same caps based on total expected costs as other
forms of federal aid, meaning the grant cannot exceed the total educational costs reported by the
institution.28 As a result, Pell grants for high school students are likely to be smaller than for
traditional postsecondary students, as they would be taking fewer credits and many states have
established tuition discounts at public institutions, or created fee exemptions for concurrently
enrolled students.29
The expansion would specifically target low-income students for participation in concurrent
enrollment programs, while also offering a general level of federal support for concurrent
enrollment. This proposal represents a scaling up of an existing experimental program launched
by the Department of Education in 2015, which provides grant money to postsecondary institutions
to implement concurrent enrollment initiatives targeted at Pell eligible students.30
Benefits of a Pay for Performance Approach to the Pell Completion Gap
Adopting a pay for performance model to address the completion gap between Pell recipients and
other students offers three advantages in comparison to traditional federal grant making efforts: it
increases efficiency in expenditure, encourages innovation at participating institutions, and ensures
sustainability for the new programs. These benefits have been documented in other initiatives in
the social sector.31 These advantages are particularly important in attempting to address the
challenges of Pell grant recipients, who are a diverse population that often faces additional
challenges impacting persistence in addition to low income. These challenges include: first-
generation student status, membership in a disadvantaged minority group, or responsibility for
dependents.32
A pay for performance model changes the incentives of traditional grant making by paying the
recipient only after agreed upon outcomes are achieved, rather than in advance based on a proposed
set of outputs. In the case of Pell recipient degree completion, this approach focuses federal
spending only on actual improvements in the completion gap, and encourages schools to maximize
efficiency.
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This model also allows schools greater flexibility in choosing which program investments it feels
will most efficiently achieve outcomes. This will encourage both innovation and diversity in
interventions. Since these interventions are likely to be tailored to the particular characteristics of
an institution’s population, they are also likely to have benefits for non-Pell recipients who may
share some of the additional barriers faced by many Pell students.
In addition, a pay for performance approach will yield more sustainable projects, since institutions
must rely on existing funds to implement their program activities. Programs that rely on internally
allocated funds would be more likely to continue even when pay for performance funds are reduced
or eliminated. Further, the pay for performance funds are not earmarked for particular activities.
Therefore, there is even less of a contingent relationship between the availability of federal dollars
and institutional activities. Even if incentive funds are received, they need not be spent on the
programs that generated them.
Pay for performance represents an efficient, innovative, and sustainable approach for the federal
government to take in addressing the bachelor’s degree completion gap between Pell recipients
and other students.
Implementing Pay for Performance
The degree completion gap is a serious issue the Pell Grant program faces when measuring its
success. A study conducted by the Education Trust found a 14% gap between Pell and non-Pell
students national college completion rate (51% to 65%).33 The Department of Education found a
similar rate which falls between 15-20%.34 However, since institutions that receive Pell Grants are
not required to disclose information on graduation rates for Pell recipients, more specific data is
not available. We propose implementing a pay for performance program for Title IV bachelor’s
degree granting institutions. The program would have two goals, first to move Pell students toward
parity in college graduation with their higher-income peers, and second to better understand what
interventions are likely to achieve this goal at the institutional level. The objective of this program
is to spur innovative and situation-specific solutions to addressing this gap, specifically for the
group of students who are not able to
benefit from concurrent enrollment
credits via the Pell Expansion
Program. Thus, schools would not be
compensated for any degrees earned
by Pell recipient students who also
received a Pell Expansion Program
grant. This would both control
program costs, and ensure a more
equitable allocation of resources
among different groups of low-
income students.
In order to address the gap, our Pay
for Performance program would
invite all bachelor’s degree granting
Gap is ≤ 3%30%
Gap is > 3%70%
Figure 2. Percent of students at institutions by Pell/non-Pell completion gap
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Title IV institutions to participate. According to the Educational Trust this represents
approximately 3000 institutions.35 Approximately 35% of schools have completion gaps of 3% or
less, and thus would be unlikely to participate.36 However, the remaining 2100 institutions likely
to participate serve 70% of the undergraduate student population.37 The reach of the program is
summarized in the graph to the right. Participating schools would sign performance agreements
that would offer to compensate the schools at a rate of $4,000 per additional degree earned by a
Pell grant recipient, excluding any Pell recipient students who also received a Pell Expansion
Program grant. Payments begin at an improvement of 1% and up to parity in their Pell vs. non-
Pell student six-year graduation rate. These performance dollars will be paid out at the close of the
six-year performance cycle. This is designed to give schools the opportunity to have at least one
cohort of students reap the full benefits of any interventions for the full period of Pell grant
eligibility.
Following the close of the initial six-year program period, an evaluation of outcomes and current
status of the completion gap between Pell and non-Pell students will be conducted using the
dramatically increased volume and quality of data on Pell student graduation rates in comparison
to the current information. This would provide an opportunity to evaluate how to better target
institutions in future pay for performance arrangements. This period of evaluation would also
allow for better assessment of the role of the Pell Expansion Program in improving completion
rates and achieving parity between Pell and non-Pell students.
Analyzing the Cost-Effectiveness of Integrated Pell Expansion and Pay for Performance
We conducted a cost-effectiveness analysis to determine the efficiency of the interventions. Cost-
effectiveness analysis uses projections of potential costs as well as possible benefits to determine
the cost per outcome of an intervention. In this case, the desired outcome is additional college
degrees, and the proposed interventions are an expansion of the Pell Grant program and a pay for
performance program for four-year colleges. The costs are those associated with making additional
grants available to high school students participating in concurrent enrollment through the Pell
program and the payment of performance incentives for universities that narrow the completion
gap. In developing our forecasts for costs and effects of each intervention, we relied on a variety
of assumptions and parameters about demographic trends, participation in higher education, and
costs which are summarized in two tables below:
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Table 1. Pay for Performance Program Assumptions
Assumptions Source
# of students enrolled in postsecondary
education (PSE) (2017) 11,022,000 National Center for Education
Statistics (NCES)
65% of institutions represent 70% of
students 80% Education Trust
College graduation rate of Pell students 51% Education Trust
College graduation rate of non-Pell
students 65% Education Trust
National education gap 12% Education Trust
FAFSA application rate 85% Office of Federal Student Aid
(OFSA)
Pell eligible rate 60% OFSA
Pell accepting rate 80% OFSA
Table 2. Pell Expansion Program Assumptions Assumptions Source Concurrent enrollment participation
growth rate- no intervention 0.5% National Center for Education
Statistics (NCES)
% high school (HS) grads to PSE 70% Bureau of Labor Statistics
(BLS)
# of HS Grads 3,328,740
NCES projection through 2023,
~0.2% average growth rate
2024-2027 Concurrent enrollment participation
growth rate- intervention 4% Jobs For the Future (JFF) report
on Colorado CE goals
Concurrent enrollment success rate 93% Colorado Department of Higher
Education Concurrent enrollment graduation rates 65% ACT Non-concurrent enrollment graduation
rates 59% NCES HS to PSE rate 66% BLS # eligible HS seniors 4,058,000 US Census Bureau
Adoption rate 4% of student population
adopts per year JFF report on Colorado CE
goals
Minimum Pell award $599.82 Office of Federal Student Aid,
1% growth rate per year
Discount rate 0.9% Office of Management and
Budget
Apply for FAFSA 85% Office of Federal Student Aid
(OFSA) Pell eligible rate 60% OFSA Pell accepting rate 80% OFSA
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Intervention Costs: Grants and Incentives
The primary costs associated with our interventions are the additional Pell grants made to high
school students through the Pell Expansion Program, and the potential payments made to schools
through the pay for performance initiative.
Pell Expansion Program
The baseline cost for Pell Grants is set at the minimum potential award for each year, which begins
at $599, and has consistently increased by about 1% per year in the past five years. 38 Our
justification is that students eligible for the Pell Grant will be earning credits in a part-time capacity
they will not have to worry about cost of living, and credits obtained through concurrent enrollment
are usually discounted for high school students within most current local level program support.
In fact, the Department of Education reports that more than half of institutions that have concurrent
enrollment students offer some discounting.39 For the purposes of this analysis, we also assume no
major change in state and local level funding for concurrent enrollment programs.40
𝐶𝑜𝑠𝑡 𝑓𝑜𝑟 𝑑𝑒𝑔𝑟𝑒𝑒𝑠 = 𝐸𝑙𝑖𝑔𝑖𝑏𝑙𝑒 12𝑡ℎ 𝑔𝑟𝑎𝑑𝑒𝑟𝑠 ∗ 𝐶𝐸 𝑎𝑑𝑜𝑝𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 ∗ 𝑃𝑒𝑙𝑙 𝑎𝑐𝑐𝑒𝑝𝑡𝑖𝑛𝑔 𝑟𝑎𝑡𝑒 ∗
𝑃𝑒𝑙𝑙 𝑎𝑤𝑎𝑟𝑑 𝑎𝑚𝑜𝑢𝑛𝑡
Pay for Performance Program
The $4000 paid per new degree is based on a median value from other equity achievement grants
provided to postsecondary institutions by the federal Fund for the Improvement of Post Secondary
Education.41 In the table below we project total program costs based on various levels of
organizational performance, ranging from 5% to a maximum of 30%, which would approximately
reach parity in college completion. We
anticipate performance outcomes at about
5% on average across all institutions,
based on analysis of the general trends and
variance in bachelor’s degree completion
rates.
𝐶𝑜𝑠𝑡 𝑓𝑜𝑟 𝑑𝑒𝑔𝑟𝑒𝑒𝑠 = 𝑃𝑒𝑙𝑙 𝑠𝑡𝑢𝑑𝑒𝑛𝑡 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 ∗ (𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 𝑖𝑚𝑝𝑟𝑜𝑣𝑒𝑚𝑒𝑛𝑡 −
𝑝𝑟𝑒𝑣𝑖𝑜𝑢𝑠 𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒) ∗ $4000
Approach to discounting costs
In evaluating both interventions we use a discount rate of 0.9% which is recommended by the
Office of Management and Budget (OMB) for cost-effectiveness analysis.42 This is considerably
more conservative than the 3.0-3.5% rate used in academic cost-effectiveness studies of education
policy interventions.43,44 Potential variance in the actual discount rate, which is typically adjusted
annually by OMB, would have an impact on the actual cost of the program.
Table 3. Pay for Performance Sensitivity Analysis
Gap Closure % Degrees Cost
30% 453,300 $1,913,300,000
15% 226,600 $956,460,000
5% 75,550 $319,000,000
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Effect: Additional Bachelor’s Degrees
Pell Expansion Program
The chart below summarizes the number of additional degrees anticipated as a result of the Pell
expansion program. We determined the number of degrees by calculating the difference in total
degrees per year with enhanced adoption of concurrent enrollment supported through Pell
expansion, and the existing trend in completion rates with no intervention. The additional degrees
are visualized in the following graph:
The formula is provided below:
𝐷𝑒𝑔𝑟𝑒𝑒𝑠 𝑒𝑎𝑟𝑛𝑒𝑑 = (𝐸𝑛𝑡𝑒𝑟𝑖𝑛𝑔 𝑃𝑆𝐸 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 ∗ 𝐶𝐸 𝑝𝑎𝑟𝑡𝑖𝑐𝑖𝑝𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 ∗ 𝐶𝐸 𝑠𝑢𝑐𝑐𝑒𝑠𝑠 𝑟𝑎𝑡𝑒 ∗
𝐶𝐸 𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒) + (𝐸𝑛𝑡𝑒𝑟𝑖𝑛𝑔 𝑃𝑆𝐸 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 ∗ (𝑁𝑜𝑛𝐶𝐸 𝑝𝑎𝑟𝑡𝑖𝑐𝑖𝑝𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 +
𝐶𝐸 𝑓𝑎𝑖𝑙 𝑟𝑎𝑡𝑒) ∗ 𝑁𝑜𝑛𝐶𝐸 𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒)
We further conducted sensitivity analysis to determine the potential impact of variance in the
adoption rate for concurrent enrollment on the
number of additional degrees earned, using
adoption rate data from Colorado as a proxy.45
Colorado was selected as it has implemented a
funding model similar to Pell at the state level.46 We
find that 4%, which is what Colorado projects to be
the most likely outcome, as the state has consistently
seen increases above 3%.47
Pay for Performance
During its six-year cycle, we calculated the additional degrees generated by the Pay for
Performance program based on national estimates of the total volume of improvement in the
completion gap across all participating institutions. Using data from the Department of Education,
1000000
1100000
1200000
1300000
1400000
1500000
1600000
1700000
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027
Figure 3: New Degrees from Pell Expansion
Expected Degrees PEP Degrees
Table 4. Pell Expansion Program Sensitivity
Analysis
Adoption Rate Degrees Cost per Degree
2% 684,500 $ 4,600
4% 2,258,700 $ 1,400
6% 2,803,700 $ 1,100
11
we estimate that the overall improvement will be a 5% reduction in the completion at participating
schools, generating an additional 75,500 degrees over six years.
𝐷𝑒𝑔𝑟𝑒𝑒𝑠 𝑒𝑎𝑟𝑛𝑒𝑑 = # 𝑠𝑡𝑢𝑑𝑒𝑛𝑡𝑠 𝑒𝑛𝑟𝑜𝑙𝑙𝑒𝑑 2017 ∗ 70% 𝑜𝑓 𝑒𝑙𝑖𝑔𝑖𝑙𝑏𝑒 𝑠𝑡𝑢𝑑𝑒𝑛𝑡𝑠 ∗𝑃𝑒𝑙𝑙 𝑎𝑐𝑐𝑒𝑝𝑡𝑎𝑛𝑐𝑒 𝑟𝑎𝑡𝑒 ∗ 𝐺𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 𝑜𝑓 𝑃𝑒𝑙𝑙 𝑠𝑡𝑢𝑑𝑒𝑛𝑡𝑠 ∗ 𝐺𝑎𝑝 𝑐𝑙𝑜𝑠𝑢𝑟𝑒 𝑟𝑎𝑡𝑒
Results
In the ten-year period between 2017 and 2027, we anticipate that our combined interventions will
yield a total of 2.3 million degrees for a total cost of about $ 3.45 billion. These additional degrees
represent a 14% increase, compared to expected number of degrees with no intervention. The full
results are summarized in the table below:
Table 5. Summarized Results
Intervention Cost 2017-2027 # Degrees 2017-2027 % New Degrees
Cost per Degree
Pell Expansion $3,100,000,000 2,250,000 13% $1,460 Pay for Performance $345,000,000 75,500 1% $4,000 Integrated $3,445,000,000 2,300,000 14% $1,500
Conclusion
The combination of the Pell Expansion Program for concurrent enrollment with the Pay for
Performance program represent an evidence-based and cost-effective approach to the dual
challenges of low postsecondary completion rates and income based disparities in college
completion. These problems limit economic growth and erode the democratic foundations of the
US government. This proposal leverages the existing successes of concurrent enrollment programs
and pay for performance programs to improve equity in college graduation, and thus fuels robust
growth in overall college completion. It is particularly effective since it manages to broadly target
low-income students of all ages, as well as creating incentives for the expansion of concurrent
enrollment and improved support services for all students. Thus, this policy can cost-effectively
help the United States meet the need for a globally competitive workforce, thriving economy, and
robust democracy.
12
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Denver, CO. Retrieved at: http://ecs.force.com/mbdata/mbprofallRT?Rep=DE14A 15 ibid, note 14. 16 Cassidy L., Keating K., Young V. (2012). Dual enrollment: lessons learned on school level lessons
learned on school-level implementation. EDJ Associates: Herndon, VA. 17 Radunzel J., Noble J., Wheeler S. (2014). Dual credit/dual enrollment coursework and long-term
college success in Texas. ACT: Iowa City, IA. 18 Belcheir, M. J. (2008). What happens to concurrently enrolled high school students who attended boise
state university during high school? Office of Institutional Research. Boise, ID. Retrieved at:
http://ir.boisestate.edu/wp-content/uploads/2011/07/rr200803concurrentenrollmentstudy.pdf 19 United States Department of Education (2013). Dual enrollment programs and courses for high school
students at postsecondary institutions: first look. Institute for Education Statistics
Washington, DC 20 Colorado Department of Education, Colorado Department of Higher Education (2015). Annual report
on concurrent enrollment 2013-2014 school year. Division of Central Services: Denver, CO. 21 ibid note 5 22 ibid note 6
13 23 ibid, note 14. 24 20 U.S.C. Ch. 28 SubCh, IV. Part A § 1070 25 30 C.F.R. § 690 26 Office of Federal Student Aid. (2015). 2015-2015 Federal Student Aid Handbook (Vols. 1, 3).
Washington, DC: US Department of Education. 27 ibid, note 14. 28 ibid, note 26. 29 ibid, note 14. 30 80 F.R. 67734 31 The Non-Profit Finance Fund (2012). Pay for Success: Investing in what works. Washington, DC
Retrieved at: http://permanent.access.gpo.gov/gpo23617/pay_for_success_report_2012.pdf 32 Ibid note 3. 33 ibid note 8. 34 U.S. Department of Education, National Center for Education Statistics, 2003-04 Beginning
Postsecondary Students Longitudinal Study, Second Follow-up (BPS:04/09). 35 ibid note 8. 36 ibid note 8. 37 ibid, note 8. 38 ibid, note 26. 39 ibid, note 19. 40 ibid, note 16. 41 United States Department of Education (2015). Fund for Innovation in Postsecondary Education
Database [Data Set]. Retrieved at: http://fipsedatabase.ed.gov/fipse/search.cfm 42 Office of Management and Budget. (2014). Circular A-94 Appendix C. Retrieved at:
https://www.whitehouse.gov/omb/circulars_a094/a94_appx-c/ 43 Levin, H., Belfield, C., Muennig, P., Rouse, C. (2006). The cost and benefits of an excellent education
for all of America’s children. Columbia University. New York, NY. Retrieved at:
http://www3.nd.edu/~jwarlick/documents/Levin_Belfield_Muennig_Rouse.pdf 44 Hollands, F.M., Hanisch-Cerda, B., Levin, H. M., Belfield, C.R., Menon, A., Shand, R., Pan, Y., Bakir,
I., & Cheng, H. (2015). CostOut - the CBCSE Cost Tool Kit. Center for Benefit-Cost Studies of
Education, Teachers College, Columbia University. Retrieved from: www.cbcsecosttoolkit.org 45 Ibid note 20. 46 Ibid note 20.
47 Ibid note 20.