ICRAS 1423 1845-0049 v8 – Affected Public – State, Local or Tribal Governments 08/19/2013

Application for Ability to Benefit Testing Approval

This request is for extension of the approval of the reporting and recordkeeping 

requirements that are contained in the information collection 1845-0049. These regulations 

govern the application for and approval by the Secretary of assessments by a private test 

publisher or State that are used to measure a student’s skills and abilities. The administration of 

approved ability to benefit (ATB) tests may be used to determine a student's eligibility for 

assistance for the Title IV student financial assistance programs authorized under the Higher 

Education Act of 1965, as amended (HEA) when the student does not have a high school 

diploma or its recognized equivalent. 

The HEA, as amended by the Consolidated Appropriation Act, 2012 (Pub. L. 112-74) 

changed the Federal student aid eligibility criteria for students without a high school diploma or 

the recognized equivalent of a high school diploma. The statute retained the completion of a 

homeschool program as an eligibility alternative, but removed the passing of an independently

administered Department approved ATB test as an eligibility criteria previously available to aid 

applicants. This change was effective for students who first enrolled in a program of study on or 

after July 1, 2012. Official guidance from the Department maintains that for students who 

previously attended an eligible program prior to July 1, 2012 and need to establish Title IV 

eligibility after July 1, 2012, the provisions of Public Law 112-74 do not apply and will not 

prevent those students from using prior ATB alternatives including passing an ATB test.

34 CFR Section 668.151 – Administration of tests.

Section 668.151(g)(4) requires that institutions where approved ATB test are given by 

certified test administrators either at assessment centers or by an independent test administrators, 

maintain the name and address of the test administrator who administered the test. 

Section 668.151(g)(5) requires that if the individual who took the test has a disability and 

as a result was unable to be evaluated by the use of a conventional test or required test 

accommodations, that documentation of the individual’s disability and of the testing 

arrangements must be maintained by the institution.

We estimate that on average it will take an institution .08 hours (5 minutes) per ATB test 

to collect and maintain the identifier information on each test administrator for each ATB test 

provided. In addition, for the ATB test takers who are individuals with disabilities that it will 

take an additional .08 hours (5 minutes) per test taker to collect and maintain documentation on 

the individual’s disability and the testing accommodations that were made by the test 

administrator for the ATB test-taker.

Section 668.151(g)(4) –requirement that institutions maintain the identifier information 

for all certified ATB test administrators.

Public Institutions : 240,882 ATB test takers X .32% (Public Institutions as a percentage 

of all participating institutions) = 77,082 X .08 hours = 6,167 hours 
ICRAS 1423 1845-0049 v8 – Affected Public – State, Local or Tribal Governments 08/19/2013

Section 668.151(g)(5) –requirement that institutions collect and maintain documentation 

of the individual ATB test-takers disability and of any accommodating provided by the certified 

test administrator to the ATB test-taker (668.151(g)(5)).

Public Institutions: 28,906 cases of individuals with disabilities taking an ATB test X .32 

(proprietary institutions as a percentage of all participating institutions) 9,250 X .08 hours 

per case reported = 740 hours

TOTALS

Responses 86,848

Respondents 86,848

Burden Hours 9,054