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Frequently Asked Questions (FAQs) and other Pertinent Information 

Model Comprehensive Transition and Postsecondary Program

(TPSID)

Since announcing the availability of grants under the 2010 Transition Programs for Students with 

Intellectual Disabilities (TPSID), the U.S. Department of Education, Office of Postsecondary Education 

(OPE), has received questions from those interested in the new program. Additionally, OPE received 

questions during a recent national technical assistance conference call (July 12, 2010) during which 

program requirements were discussed. The following are responses to the many questions we have 

received. For additional information, please consult the TPSID application packet available at 

http://www.ed.gov/programs/tpsid, the Higher Education Opportunity Act (HEOA) statute 

(http://www2.ed.gov/policy/highered/leg/hea08/index.html), and the final regulations, which include 

clarifying language related to institutional participation in Title IV Federal student aid programs 

http://edocket.access.gpo.gov/2009/E9-25373.htm.

Readers should be aware of the differing application requirements under the TPSID program and the 

requirements for institutions that are interested in applying to the U.S. Office of Federal Student Aid 

(FSA), to have their comprehensive transition and postsecondary program deemed eligible to participate 

in Title IV Federal student aid programs. For more information about the process and requirements 

related to Federal student aid, please read the electronic announcement posted to the FSA Information 

for Financial Aid Professionals Web site at http://www.ifap.ed.gov/ifap/index.jsp.

NOTE TO ALL APPLICANTS: 

THE INFORMATION BELOW SHOULD BE COUPLED WITH A CAREFUL REVIEW OF THE TPSID 

APPLICATION PACKAGE AND THE REQUEST FOR PROPOSAL. THE SAME GUIDANCE APPLIES TO 

APPLICANTS FOR THE TPSID COORDINATING CENTER.

ELIGIBLE APPLICANTS

All applicants must meet the definition of Institution of Higher Education (IHE) as it is defined in the 

TPSID application package. Non-profit, private, degree conferring institutions of higher education are 

allowed to be a part of the consortium of IHEs. This includes two-year colleges and community colleges.

Can a UCED be the lead applicant if we apply as a consortium of IHEs?

The program legislation does not prohibit an IHE who will not have the program at their IHE from serving 

as the lead applicant.

Experienced and inexperienced applicants must independently decide the role they would like their 

UCED (University Center for Excellence in Disability) to play with regards to their comprehensive 

transition programs. All eligible applicants will want to consider a role that is in the overall best interest 

of their program/project. Applicants that decide to allow an IHE other than the one who will have the 

comprehensive transition and postsecondary program at their IHE serve as the lead applicant may want 

to consider how the grant would benefit by having the IHE who is not going to have the comprehensive 

transition program at their school, serve as the lead applicant.
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Additionally, if you decide to make the UCED the lead entity (although it would not be the entity with 

the comprehensive transition program at your IHE), please be sure to consider whether or not this may 

(or may not) affect the evaluation of the comprehensive transition program (because all applicants who 

receive grants under this program will have specific reporting requirements they must meet as a result 

of accepting a grant under the TPSID program) and/or may (or may not) effect you as the lead entity's 

ability to ensure that the goals of the program are met.

Also please note that, for the duration of the project, the IHE to whom TPSID funds are obligated will 

remain the fiscal agent for the project.

Are proprietary schools (IHEs) eligible to participate in the TPSID program?

No.

NUMBER OF GRANT AWARDS

How many grants will be awarded to creating a program vs. how many to enhancing a program?

OPE will not be considering the percentage of projects that will be funded based on where the project is 

in the development phase. It is expected that there will be a range of approved applications fundedrepresenting the continuum of development. The learning that emanates from these models and the 

coordinating center will be important in future years to reach out to new programs and encourage their 

participation in the TPSID program. 

TPSID PROJECT START DATE INFORMATION

Can the first year be used as a planning year?

Effective October 1, 2010, those selected to receive awards under the TPSID program will have access to 

their grant awards. Additionally, each grantee has reporting requirements that must be met on an 

annual basis. The reporting period will begin October 1, 2010.

PAGE LIMITATION INFORMATION

TPSID program page limitation information

Applicants are required to adhere to the page limitation in the Application Narrative Instruction portion 

of the application. The “Notice Inviting Applications” for new awards for FY 2010, published in the 

Federal Register contains specific information governing page limits for each grant type and formatting 

instructions. The page limit for the project narrative portion of the application for the FY 2010 TPSID 

competition is 40 pages.

There is no limitation on the number of pages one may download into appendices 1-3 (listed on page 79 

of the TPSID application). Optional appendices #4 should be five pages or less.

File Attachment Information

File attachment information is located on pages 20-22 of the TPSID application package.
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How many letters of support should one include in their TPSID application?

There is no limitation on the number of letters of support one may submit with their TPSID application, 

but applicants are asked to please reasonable when making that determination.

ON-CAMPUS HOUSING FOR ID STUDENTS PARTICIPATING IN THE TPSID PROGRAM

The Department recognizes that there are a myriad of possible arrangements that an institution may 

have for housing facilities for students. Regarding whether a particular student housing facility is an “oncampus'' facility, we refer to the current definition of the term “campus” in Section 668.46(a). To clarify, 

any student housing facility that is owned or controlled by the institution, or is located on property that 

is owned or controlled by the institution, and is within the reasonably contiguous geographic 

area that makes up the campus is considered an on-campus student housing facility.

TPSID COORDINATING CENTER

The purpose of the TPSID Coordinating Center, (which is a five-year cooperative agreement) is to 

establish a coordinating center for institutions of higher education that offer inclusive comprehensive 

transition and postsecondary programs for students with intellectual disabilities, including institutions 

funded under the Transition Programs for Students with Intellectual Disabilities (TPSID) Program

(http://www.ed.gov/programs/tpsid).

An applicant funded to operate the coordinating center will be required to work closely with all 

comprehensive transition and postsecondary programs, including the TPSID grantees funded under 

section 767 of the Higher Education Act of 1965, as amended (HEA). The coordinating center will 

provide technical assistance to IHEs that offer comprehensive transition and postsecondary programs 

for students with intellectual disabilities, and will work with these programs to evaluate program 

components and recommend standards for such programs. 

The coordinating center is expected to build the knowledge base around evidence-based components of 

comprehensive transition and postsecondary programs by designing protocols, and collecting, storing, 

analyzing and reporting on program components and outcomes; providing technical assistance and 

disseminating information to all comprehensive transition and postsecondary programs, including those 

funded under the transition programs for students with intellectual disabilities into higher education 

(TPSID) discretionary grant program (84.407A); and serving as a leader and coordinating communication 

strategies about comprehensive transition and postsecondary programs.

USE OF GRANT FUNDS

There are nine areas ALL TPSID applicants must address as they establish their model comprehensive 

transition and postsecondary program for students with intellectual disabilities. These areas may be 

found on pages 26-28 of the TPSID application package.

Are there expectations on how different dollars (IDEA, vs. grant vs. IHE) are spent? 

IDEA dollars are guided by the needs of the students as determined in the students IEP as appropriate. 

The use of IDEA dollars must be according to the cost rules of IDEA funding, and always aligned with the 

needs of students based on the student’s individualized education program. There is a 25 percent
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matching requirement in the TPSID program. This contribution can be in fiscal contributions, or other inkind contributions that an institution can offer. The entire TPSID budget is not intended to supplant 

existing program resources that are being used if the institution already has a comprehensive transition 

and postsecondary program in place. Rather, the TPSID grant is used to extend the scope, breath, or 

depth of the existing comprehensive transition and postsecondary program. There is requirement for 

TPSID grants to build sustainable programs – this can best be accomplished if institutions contribute and 

support the program early in its development.

ALLOWABLE COSTS

Please refer to EDGAR (Education Department General Administrative Regulations) for information 

regarding “allowable” costs. You may access EDGAR at 

http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html. 

You may also refer to Office of Management and Budget (OMB) circulars for such guidance via the 

following Web site: http://www.whitehouse.gov/omb/circulars/. 

The following circulars cited are also utilized to assist in determining allowable costs: A-87 - Cost 

Principles for State, Local and Indian Tribes; A-21 - Cost Principles for Educational Institutions; and A-122

- Cost Principles for Non-Profit Agencies.

BUDGET REQUIREMENT FOR IHEs

Applicants must clearly describe the contributions of LEA (local education agency) partners to the 

project, for each budget year.

OPE discretionary grants, and specifically, these comprehensive transition and postsecondary program 

grants are required to follow the rules of allowable and unallowable expenses directed by EDGAR. The 

priority does not require that grantees allocate their resources in any particular ways – although, since 

these are model demonstration grants, when considering the scope of work, reviewers may assess 

whether TPSID applicants have provided enough resources for evaluation activities, and to the activities 

specified within the use of funds directions. Reviewers will likely look for sufficient resources dedicated 

to activities that facilitate the students participation in the academic, social, work experience, and 

independent living sectors of a higher education setting. Applications will also be examined to 

determine whether the proposed work for this program is aligned with the intent of the priority. For 

instance, if an applicant proposed 100 percent of its resources for staff development – it would be 

unlikely that it could sufficiently meet the other use of funds requirements. An applicant should 

consider alternate funding sources such as those also within OPE, such as the model demonstrations for 

faculty (84.333A) or grants funded by the Office of Special Education Programs (OSEP).

BUDGET CONSIDERATION LEAS

Please be sure to carefully consider what is being proposed via the IHEs comprehensive transition and 

postsecondary program vs. what IDEA (and other pertinent sources) is/are required/willing to pay for.

Can applicants budget more than $4,000 towards the TPSID Coordinating Center?

Each applicant may determine this on an individual basis.
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LOCATION OF THE BUDGET NARRATIVE IN THE TPSID APPLICATION

The budget narrative should be included in the “Project Narrative – Adequacy of Resources” section of 

the TPSID application. For those interested in including a more detailed budget narrative, you may do so 

via the Appendix 4 - Optional section of the TPSID application. The 524B budget form is to be included in 

Sections A&B of the TPSID application. Page 59 of the TPSID application provides instructions for 

completing the application package. 

TPSID PROGRAM GPRA PERFORMANCE INDICATORS

TPSID Government Performance and Results Act (GPRA) performance indicators are located on page 57 

of the TPSID application package. All applicants must address them in their submitted applications.

TPSID PROGRAM EVALUATION REQUIREMENTS

Additional evaluation requirements for TPSID program applicants are covered on pages 6, 18, 46-49 of 

the application package. 

Other questions TPSID program applicants were asked to address are: 

* the types of data that will be collected;

* the data collection timeframe, methods, and instruments;

* what data analyses and reporting methods will be used; 

* how the project will use these data to continuously improve their project.

TPSID applicants should note that all TPSID grantees will work closely with the TPSID Coordinating 

Center funded under Section 777 (b) to develop performance measures more closely aligned with this 

work. Please also note that there are TWO performance measures located in the TPSID Coordinating 

Center application package and they are as follows:

(1) The percentage of recipients that have grants authorized under the TPSID program that meet 

Department-approved, center-developed standards for necessary program components, reported 

across each standard; and 

(2) The percentage of students with intellectual disabilities who are enrolled in programs funded under 

TPSID who complete the programs and obtain a meaningful credential, as defined by the center and 

approved by the Department.

DEFINITION OF AN INSTITUTION OF HIGHER EDUCATION FOR THE PURPOSE OF THE TPSID PROGRAM

Institution of Higher Education. For purposes of this Act, other than Title IV, the term ‘institution of 

higher education' means an educational institution in any State that--

(1) admits as regular students only persons having a certificate of graduation from a school providing 

secondary education, or the recognized equivalent of such a certificate or persons who meet the 

requirements of Section 484(d)(3);
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(2) is legally authorized within such State to provide a program of education beyond secondary 

education;

(3) provides an educational program for which the institution awards a bachelor's degree or provides 

not less than a two-year program that is acceptable for full credit toward such a degree or awards a 

degree that is acceptable for admission to a graduate or professional degree program, subject to review 

and approval by the Secretary;

(4) is a public or other nonprofit institution; and

(5) is accredited by a nationally recognized accrediting agency or association, or if not so accredited, is 

an institution that has been granted preaccreditation status by such an agency or association that has 

been recognized by the Secretary for the granting of preaccreditation status, and the Secretary has 

determined that there is satisfactory assurance that the institution will meet the accreditation standards 

of such an agency or association within a reasonable time.

(b) ADDITIONAL INSTITUTIONS INCLUDED.—For purposes of this Act, other than Title IV, the term 

‘‘institution of higher education’’ also includes—

(1) any school that provides not less than a one-year program of training to prepare students for gainful 

employment in a recognized occupation and that meets the provision of paragraphs (1), (2), (4), and (5) 

of subsection (a); and

(2) a public or nonprofit private educational institution in any State that, in lieu of the requirements in 

subsection (a)(1), admits as regular student individuals—

(A) who are beyond the age of compulsory school attendance in the State in which the institution is 

located; or

(B) who will be dually or concurrently enrolled in the institution and a secondary school. (Section 101. 

General Definition of an Institution of Higher Education (http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=110_cong_public_laws&docid=f:publ315.110).

DEFINITION OF A “STUDENT WITH AN INTELLECTUAL DISABILITY” FOR THE PURPOSE OF THE TPSID 

PROGRAM – THIS DEFINITION WAS DEFINED MORE FULLY IN THE FINAL REGULATIONS WHICH 

CLARFIED PROPOSED RULES FOR THE TITLE IV, FEDERAL STUDENT AID PROCESS. TEXT FROM THOSE 

CLARIFICATIONS IS INCLUDED BELOW.

Student with an Intellectual Disability. The term ‘student with an intellectual disability’ means a 

student—(A) with mental retardation or a cognitive impairment, characterized by significant limitations 

in—(i) intellectual and cognitive functioning; and(ii) adaptive behavior as expressed in conceptual, 

social, and practical adaptive skills; and (B) who is currently, or was formerly, eligible for a free 

appropriate public education under the Individuals with Disabilities Education Act (20 U.S.C. 1140 

Section 760(2) http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=110_cong_public_laws&docid=f:publ315.110.pdf).

Additionally, the Department recognizes that disabilities other than mental retardation, such as certain 

forms of autism and traumatic brain injury, may be considered intellectual disabilities, under Section

668.233(c), a student with an intellectual disability is eligible to receive Federal Pell, Federal 
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Supplemental Educational Opportunity Grant, and Federal Work Study program assistance under

subpart O of part 668 (Financial Assistance for Students with Intellectual Disabilities) if the institution 

that offers the eligible comprehensive transition and postsecondary program obtains a record from a 

local educational agency (LEA) that the student is or was eligible for special education and related 

services under the IDEA.

Additionally, if that record does not specifically identify the student as having an intellectual disability, 

the institution must review all documentation obtained, such as a documented comprehensive and 

individualized psycho-educational evaluation and diagnosis of an intellectual disability by a psychologist 

or other qualified professional; or a record of the disability from an LEA or State educational agency 

(SEA), or government agency, such as the Social Security Administration or a vocational rehabilitation 

agency, that identifies the intellectual disability. Ultimately, the institution determines whether a 

student meets the definition of a student with an intellectual disability for the purpose of this subpart.

The Department interprets the statute as providing that a student who has not gone through the formal 

IDEA eligibility process does not meet the definition of a student with an intellectual disability. 

Specifically, Section 760(2) states that a student with an intellectual disability means a student who 

“is currently, or was formerly, eligible for a FAPE under the IDEA.'' While the Department does not wish 

to exclude students who have not gone through this process, we do not believe the statutory language 

permits the Department to make these students eligible. The Department encourages students to 

obtain an IDEA eligibility determination.

Does the definition of ID include individuals on the ASD?

The comprehensive transition and postsecondary program is targeted at providing access to 

postsecondary education to those students who traditionally have been unable to participate in higher 

education. If a student with ASD has a significant cognitive impairment with significant limitation in 

cognitive functioning, and limitations in adaptive behavior, and who was formerly or currently eligible 

for IDEA services, that student does meet the definition of an eligible student.

If a student with ASD does not meet this definition, and their disability does not present any significant 

intellectual or cognitive functioning or adaptive behavior, the student may be admitted to the 

institution, and may be considered a student with a disability, and thus entitled to disability support 

services and/or accommodations consistent with other Federal policy such as Section 504 of the 

Rehabilitation Act or the American with Disabilities Act. 

Is there any additional guidance regarding the definition of “meaningful credential”?

This is a determination that applicants must make on an individual basis. Applicants seeking additional 

information in the area of “meaningful credential” will likely uncover such information during their own 

literature review process and/or may want to consider conferring with other IHEs or similar entities that 

have existing comprehensive transition and postsecondary programs for students with intellectual 

disabilities. Additionally, some of the materials referenced on pages 7-9 of the TPSID application 

package may be of assistance to you as well.

Assessing “Inclusiveness” as it relates to the model comprehensive transition and postsecondary 

programs applicants are developing for the TPSID program.
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In an amended regulation – “(E) Requires students with intellectual disabilities to be socially and 

academically integrated with non-disabled students to the maximum extent possible (Section 760, 20 

U.S.C. 1140)."

If you are trying to assess the "inclusiveness" of a student's program - IHEs may also want to consider 

questions like: whether there is any potential least restrictive environment in which the content of the 

course can be delivered? Whether or not an existing course can be adapted to address the 

knowledge/content delivered in a segregated setting? Has the program considered all possible less 

segregated options in which the student can learn the course content, instead of being placed in a 

segregated class or experience?

Each applicant must utilize the information provided to shape how they plan to address “inclusiveness” 

as it relates to the model comprehensive transition and postsecondary programs for students with 

intellectual disabilities you are in the process of developing or expanding. 

DETERMINING THE MEANING OF “HALF-TIME BASIS.” THE REQUIREMENTS FOR PROGRAM 

PARTICIATION IN TITLE IV MAY BE DIFFERENT, THUS, READERS ARE ENCOURAGED TO REVIEW THE FSA 

PROGRAM REQUIREMENTS AT http://www.ifap.ed.gov/ifap/index.jsp.

In determining the meaning of half-time participation in designing a comprehensive transition and 

postsecondary program, it may be reasonably based on real hours, credit hours, or a combination of the 

two. It may be calculated across the span of the program or by term, as long as an institution clearly 

explains in its application to add an eligible program how this will be determined. Half-time 

participation may be calculated per semester or across the length of the comprehensive transition and 

postsecondary program. 

Without speaking on behalf of the authors of the TPSID legislation, it is believed not stating an exact 

number of college credits needed by ID students to successfully complete a model comprehensive 

transition postsecondary program was done intentionally to enable applicants a bit more flexibility in 

this area because, each program will be offering different course work/curriculum to its student 

participants. The amount of time it may take for the students to complete each applicant's respective 

program, will also vary.

DEFINITION OF COMPREHENSIVE TRANSITION AND POSTSECONDARY PROGRAM

Comprehensive transition and postsecondary program for students with intellectual disabilities

(Section 760(1) of the Higher Education Act). The term “comprehensive transition and postsecondary 

program for students with intellectual disabilities” means a degree, certificate, or nondegree program 

that meets each of the following:

(A) Is offered by an institution of higher education.

(B) Is designed to support students with intellectual disabilities who are seeking to continue academic, 

career and technical, and independent living instruction at an institution of higher education in order to 

prepare for gainful employment.

(C) Includes an advising and curriculum structure.

(D) Requires students with intellectual disabilities to participate on not less than a half-time basis as 

determined by the institution, with such participation focusing on academic components, and occurring 

through one or more of the following activities:
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(i) Regular enrollment in credit-bearing courses with nondisabled students offered by the 

institution.

(ii) Auditing or participating in courses with nondisabled students offered by the institution for 

which the student does not receive regular academic credit.

(iii) Enrollment in noncredit-bearing, nondegree courses with nondisabled students.

(iv) Participation in internships or work-based training in settings with nondisabled individuals.

(E) Requires students with intellectual disabilities to be socially and academically integrated with nondisabled students to the maximum extent possible.

TPSID PROGRAM PARTICIPANT INFORMATION

Can students who have been home schooled and/or who have gone to private school participate in 

the TPSID program? 

Yes. However, these students must have been or in the future, would have to go through an IDEA 

eligibility determination process and determined to be an eligible for IDEA services, regardless of 

whether they actually did receive or will receive services under IDEA.

Age range of the students with intellectual disabilities who are to be served via the TPSID program

The program legislation does not specify the age range of the students with intellectual disabilities. 

Applicants’ comprehensive transition and postsecondary programs are to serve students with 

intellectual disabilities or are currently, or were formerly, eligible for a free appropriate public 

education under the Individuals with Disabilities Education Act (20 U.S.C. 1140 Section 760(2)).

Age limit for ID students who participate in the model comprehensive transition and postsecondary 

programs for students with intellectual disabilities.

Although the program legislation does not specify an age limit for the ID students enrolled in the model 

comprehensive transition and postsecondary programs, however, please keep in mind that individual 

IHEs may have their own enrollment requirements.

Number of years of the model comprehensive transition and postsecondary program for students 

with intellectual disabilities being served under the TPSID program

The program legislation does not specify the number of years that may be considered to be appropriate 

for a model, however, the application includes the following requirement, “students with intellectual 

disabilities to participate on not less than a half-time basis, as determined by the institution, with such 

participation focusing on academic components, and occurring through one or more of the following 

activities; 

Additionally, an amended regulation, (E) requires students with intellectual disabilities to be socially and 

academically integrated with non-disabled students to the maximum extent possible (section 760, 20 

U.S.C. 1140). 

May non-traditional/older students with ID participate in the TPSID program?

The program regulations do not prohibit, non-traditional/older adult ID students from participating in 

the TPSID program.
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Applicants who may be considering targeting adult ID students may also want to consider:

IHEs must have written, verifiable documentation that the adult ID students were deemed eligible for 

IDEA (the students are currently or were formerly, eligible for a free appropriate public education under 

the Individuals with Disabilities Education Act (20 U.S.C. 1140 Section 760 (2));

TPSID grant funds cannot be used for direct financial aid and can only be used for TPSID program 

support and services;

A gentle reminder regarding definition of a student with an intellectual disability:

(A) with mental retardation or a cognitive impairment, characterized by significant limitations in (i) 

intellectual and cognitive functioning; and

(ii) adaptive behavior as expressed in conceptual, social, and practical adaptive skills; and

(B) who is currently, or was formerly, eligible for a free appropriate public education under the 

Individuals with Disabilities Education Act (20 U.S.C. 1140 Section 760(2)).

The final regulations pertinent to Title IV, program participation in financial aid provides additional 

clarification regarding the institution’s responsibility to document a student’s disabilities. 

Additionally, the Department recognizes that disabilities other than mental retardation, such as certain 

forms of autism and traumatic brain injury, may be considered intellectual disabilities, under Section

668.233(c) , a student with an intellectual disability is eligible to receive Federal Pell, Federal 

Supplemental Educational Opportunity Grant (FSEOG), and Federal Work Study (FWS) program 

assistance under subpart O of part 668 (Financial Assistance for Students with Intellectual Disabilities) if 

the institution that offers the eligible comprehensive transition and postsecondary program obtains a 

record from a local educational agency (LEA) that the student is or was eligible for special education and 

related services under the IDEA.

Additionally, if that record does not specifically identify the student as having an intellectual disability, 

the institution must review all documentation obtained, such as a documented comprehensive and 

individualized psycho-educational evaluation and diagnosis of an intellectual disability by a psychologist 

or other qualified professional; or a record of the disability from an LEA or SEA, or government agency, 

such as the Social Security Administration or a vocational rehabilitation agency, that identifies the 

intellectual disability. Ultimately, the institution determines whether a student meets the definition of a 

student with an intellectual disability for the purpose of this subpart.

 

Other considerations TPSID applicants who are considering targeting non-traditional/older adult ID 

students may want to keep in mind: 

(1) The funding support for these non-traditional/adult ID students since grant funds cannot be used for 

direct student assistance;

(2) The level of "buy in" you will need to obtain from the IHE administration;

(3) Recruiting efforts for these non-traditional ID students (especially in the event they are to 

participate in on-campus housing; and
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(4) Plans for sustainability of your potentially funded TPSID grant beyond federal funding.

Dually enrolled students who participate in a model comprehensive transition and postsecondary 

program via the TPSID program. Information for the below response was in part taken from the final 

regulations related to Title IV program participation in Federal Student Aid.

It is the Department's longstanding position that a student with a disability may be dually enrolled in 

secondary school and a postsecondary institution, although such dual enrollment precludes the student 

from being eligible for Title IV, HEA aid.

The provisions in section 612(a)(2) of the IDEA and 34 CFR 300.110 require States to ensure that public 

agencies take steps to ensure that children with disabilities have access to the same program options 

that are available to nondisabled children in the area served by the agency. This would apply to dual 

enrollment programs in postsecondary or community-based settings. However, we do not believe that 

the IDEA, or its implementing regulations, requires public agencies to provide dual enrollment programs 

in postsecondary or community-based settings for students with disabilities, if such programs are not 

available to secondary school students without disabilities. 

In a State that offers dual enrollment programs to secondary school students, a high school student with 

an intellectual disability, as defined under Section 668.231(b), who is receiving special education and 

related services may be dually enrolled in an eligible comprehensive transition and postsecondary 

program under Section 668.232.

Also, please keep in mind the fact that, if an applicant is awarded a TPSID grant, this does not necessarily 

indicate that the applicant’s program will be deemed eligible to participate in federal student aid 

programs. All institutions that offer a comprehensive transition and postsecondary program, if they are 

interested in participating in federal student financial aid programs, and regardless of whether they are 

a TPSID grantee, must apply to FSA to determine whether this additional program is an eligible program. 

Similarly, if a comprehensive transition and postsecondary program has already applied to FSA, and their 

program was determined to be eligible to participate in federal student aid programs, this does not 

necessarily indicate that the applicant will be successful in procuring a TPSID grant. 

Also, in connecting with an appropriate U.S. Department of Education Financial Student Aid employee, 

applicants who do not know this already may want to receive additional information regarding the 

interaction between the receipt of Title IV, HEA aid and other benefits that the student may receive, 

such as Medicaid or vocational rehabilitation funding.

DEVELOPING A MODEL COMPREHENSIVE TRANSITION AND POSTSECONDARY PROGRAM FOR

STUDENTS WITH INTELLECTUAL DISABILITIES WHO WILL BE SERVED VIA THE TPSID PROGRAM.

Many of the following questions and responses were taken from the final regulations related to 

program participation in Title IV Federal student aid.

The ''program'' will be so different for each person and the length of it may be different for each 

person. It may be challenging to determine how to award a certificate since each person may require 

certain things to feel completed. Please clarify?
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Each applicant will need to determine these factors on an individual basis. Applicants seeking more 

detailed information will likely uncover such information during the literature review process and/or 

may want to consider conferring with other IHEs or similar entities that have existing comprehensive 

transition and postsecondary programs for students with intellectual disabilities. Some of the referenced 

information provided on pages 7-9 of the TPSID application package may be of assistance to you.

The concept of a “program” is different in special education than it is in higher education

In general, an institution must demonstrate in its application that its comprehensive transition and 

postsecondary program satisfies the definitional criteria in Sec. 668.231(a). An institution may have one, 

or more than one, comprehensive transition and postsecondary program. A program may be for only 

one student or for a group of students, but each program must be approved by the Department. To be 

clear, the Department will not approve a generalized structure that can later be modified by the 

institution to be a different program for specific students. That said, once a program is approved, it can 

be modified slightly for different students. For example, a program approved under Section 668.231 

may require a specific number and type of courses, along with other program requirements, but that 

does not mean that each student in that program will take exactly the same courses. Much like the 

variation in any student’s curriculum that results from individual choices in elective coursework and 

required academic areas within a program, individual students enrolled in an approved comprehensive 

transition and postsecondary program may end up taking some different courses. All such courses must 

be part of the same approved program or part of a separately approved program.

The importance of employment as a desired outcome for students with intellectual disabilities who 

enroll in eligible comprehensive transition and postsecondary programs.

Gainful employment is an important outcome for students with intellectual disabilities participating in 

comprehensive transition and postsecondary programs. In fact, the Department has a long history of 

providing national leadership for, and administration of, programs that develop and implement 

comprehensive and coordinated programs of vocational rehabilitation, supported employment and 

independent living for individuals with disabilities, through services, training and economic 

opportunities, in order to maximize their employability, independence and integration into the 

workplace and the community.

The Department believes that the regulations sufficiently ensure that the comprehensive transition and 

postsecondary programs approved by the Department will focus on ensuring that enrolled students will 

be prepared for gainful employment. Specifically, in the definition of the term comprehensive transition 

and postsecondary program in Section 668.231, paragraph (a)(3) provides that the program is one that is 

designed to support students with intellectual disabilities who are seeking to continue academic, career 

and technical, and independent living instruction at an institution of higher education in order to 

prepare for gainful employment. Under Section 668.232(a), an institution applying to offer a 

comprehensive transition and postsecondary program as an eligible program under Title IV of the HEA 

must provide to the Secretary a detailed description of that program, including a description that 

addresses all of the components of the program, as defined in Section 668.231. Because Section 

668.231(a)(3) specifically references that a comprehensive transition and postsecondary program is one 

that is designed to prepare enrolled students for gainful employment, the detailed description required 

under Section 668.232(a) must include a description of how the program meets this definitional 

requirement. We, therefore, believe that the regulations sufficiently ensure that any comprehensive 
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transition and postsecondary program will focus on the outcome of gainful employment for students 

participating in these programs.

The process for adding a model comprehensive transition and postsecondary program to the list of 

eligible programs at an institution of higher education

The process for adding a model comprehensive transition and postsecondary program to the list of 

eligible programs at an institution of higher education should not pose a large burden on institutions, 

because it will be part of the same process an institution now uses to notify the Department of any new 

program it seeks to include as an eligible Title IV, HEA program. As far as the model demonstration and 

coordinating center, the Department has a current National Institute of Disability and Rehabilitation 

Research Center evaluating promising practices in this area.

State and LEA requirements as they relate to the TPSID program 

Under Section 612(a)(1) of the IDEA and 34 CFR 300.101, each State and its LEAs must make FAPE (free 

appropriate public education) available to all children with specified disabilities residing in the State, in 

mandatory age ranges. Under 34 CFR 300.17(c) of the regulations implementing Part B of the IDEA, FAPE 

includes an appropriate preschool, elementary school, or secondary school education in the State 

involved. Under the IDEA, LEAs are not required to provide FAPE in postsecondary education settings. 

In general, Part B, IDEA funds could be used for appropriate education services included in an IEP that 

are provided outside of a public or private elementary or secondary school though, if, under State law, 

the education would be considered secondary school education.

A student with an intellectual disability is eligible to receive Federal Pell Grant, FSEOG, and FWS program 

assistance under Section 668.233 if the student satisfies the general student eligibility requirements 

under Section 668.32, except for paragraphs (a), (e), and (f) of that section. Section 668.32(b) states 

that a student is not eligible to receive Federal Pell Grant, FSEOG, or FWS program assistance if he or she 

is enrolled in elementary or secondary school. In other words, if a student is dually enrolled in a 

secondary school and an eligible comprehensive transition and postsecondary program, he or she is not 

eligible for Federal Pell, FSEOG, and FWS program assistance. Therefore, while an LEA could use Part B, 

IDEA funds to support a dually enrolled student with a disability's participation in a comprehensive 

transition and postsecondary program if the services the student received in that program were 

considered secondary school education under State law and were included in the student's IEP, the 

student would not be eligible to apply for Federal Pell Grant, FSEOG, and FWS program assistance.

IDEA’s Child Find and Free and Appropriate Public Education (FAPE) in the least restrictive environment 

requirements apply to all individuals who are still at an age at which they could receive special 

education services in their state.

If a student with an intellectual disability who is dually enrolled in a comprehensive transition and 

postsecondary program receives services in that program that are considered secondary education in 

the State and are included in the student's IEP, the SEA or LEA must monitor the student's progress 

toward annual academic and functional goals, because those entities are responsible, under the IDEA, 

for ensuring that the services identified in the student's IEP are provided. Additionally, eligible 

comprehensive transition and postsecondary programs, which operate through institutions, must meet 
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the program requirements in Section 668.232, including establishing a policy for determining whether a 

student enrolled in the comprehensive transition and postsecondary program is making satisfactory 

academic progress. In all cases, the Department encourages the SEA or LEA and the institution offering 

the comprehensive transition and postsecondary program to enter into a formal agreement of 

understanding that identifies what the SEA or LEA will provide to the dually-enrolled student, and what 

the institution will provide to meet the requirements of an eligible comprehensive transition and 

postsecondary program, and how the student's progress will be assessed. Furthermore, Section 

612(a)(12) of the IDEA and its implementing regulations at 34 CFR 300.154 require States to develop and 

implement interagency agreements or other written mechanisms for interagency coordination to ensure 

that services necessary to provide FAPE to children with disabilities within the State that are provided or 

paid for by other public agencies are provided or paid for. These provisions mean that if public agencies 

of a State operate comprehensive transition and postsecondary programs that dually enroll students 

who are covered by the IDEA to provide services included in the students' IEPs, the State must ensure 

that interagency agreements or other written mechanisms meeting these requirements are in place.

Vocational rehabilitation participation as it relates to the TPSID program

Transition planning involves an interdisciplinary effort – including work across special education and 

vocational rehabilitation (VR). Applicants are encouraged to review literature from both special 

education and vocational rehabilitation researchers to identify those evidence-based practices that are 

proven successful in breaking down silos. Applicants are encouraged to invite the participation of VR 

professionals early in the development and launch of the comprehensive transition and postsecondary 

program. Provide opportunities for VR professionals to advise or consult to your program and establish 

ongoing communication mechanisms and dedicated staff to ensure the relationships are sustained. 

Students who leave the TPSID program and are successful in gainful employment would also be the 

interest of vocational rehabilitation personnel and would positively affect their closure rate – data that 

is used to measure the performance of vocational rehabilitation.

What type of commitment should applicants receive from vocational rehabilitation? Is a commitment 

letter needed or a letter of support?

The TPSID program legislation does not specifically address this. It is likely that applicants who are 

interested in a concrete commitment with those entities they plan to work in partnership with, will have 

some sort of written agreement outlining the terms of the commitment so that all pertinent parties will 

be clear about what is expected of each entity for the timeframe specified in the written agreement.

What can be used to meet the TPSID matching requirement?

Cash and in-kind (personnel, space, equipment) are examples of match. Donated time may be used as 

cost share because the persons working on a grant are not being paid for the time that they are working.

The TPSID program has an eight percent indirect cost rate cap. Unrecovered indirect costs (IHEs who 

have negotiated indirect cost rates well above eight percent who may be seeking to utilize the 

remaining indirect costs that they were unable to utilize because of the eight percent cap) percent of 

indirect costs that remains MAY NOT be used to meet the match under the TPSID program.

Please note: The matching requirement can not be met with federal funds.