6. Enrollment in an Educational Program Less Than Half-Time

Under section 1902(xx)(2)(D) of the Act, an applicable individual demonstrates community engagement if the individual is enrolled in an educational program at least half-time. As noted in section II.C.4. of this IFC, new § 435.552(b) explains the meaning of educational program, and § 435.552(c) describes that full-time, half-time, or less than half-time enrollment is to be determined by the institution or school. However, consistent with section 1902(xx)(2)(E) of the Act, education hours accrued by an individual enrolled in an educational program less than half-time may be combined with hours performed for other community engagement activities to count towards demonstrating community engagement. Next, we discuss how educational program hours should be counted when an individual is enrolled less than half-time.

As stated in new § 435.552(d), when a school determines that an applicable individual is enrolled less than half-time in an educational program that uses credit hours, then 1 credit hour counts as 3 education hours per week during the individual's enrollment. For example, 1 credit hour equals 1 hour of instruction, and we expect students to spend 2 hours on out-of-class work for a total of 3 hours of time spent in the educational program for the week. To calculate the time spent in the educational program for a 1 credit hour course during a 1-month period, this would be 3 hours a week multiplied by 4.33 weeks (in a month) [ 33 ] for a total of 12.99 hours in a month. This new standard is based on the Carnegie Unit, which defines 1 unit of credit as equal to 3 hours of student work per week (1 hour of lecture plus 2 hours of homework). [ 34 ] The Carnegie Unit is used in the credit hour definition at 34 CFR 600.2 . As noted in ED guidance provided to institutions and accrediting agencies regarding the credit hour, “A credit hour for Federal purposes is an institutionally established equivalency that reasonably approximates some minimum amount of student work reflective of the amount of work expected in a Carnegie unit: key phrases being “institutionally established,” “equivalency,” “reasonably approximates,” and “minimum amount.” [ 35 ] Under the definitions at 34 CFR 600.2 , a credit hour must reasonably approximate not less than 1 hour of classroom or direct faculty instruction and a minimum of 2 hours of out-of-class student work each week, or at least an equivalent amount of work for other academic activities as established by the institution. [ 36 ]

We decided upon this credit hour standard because it allows for consistency across schools and programs and provides a straightforward way to account for instructional time and student work. This standard is also ( printed page 33359) consistent with the ED standards described here. For example, ED provides standards that institutions can use to determine full-time and half-time student status for purposes of participation in financial assistance programs. The following ED standards are illustrative. The full-time student standard for a program that measures progress in credit hours is 12 semester hours for an academic term (see full-time student definition at 34 CFR 668.2(b) ). A half-time student should have a workload, as determined by the institution, that amounts to half of the workload of the applicable minimum requirement of a full-time student (see half-time student definition at 34 CFR 668.2(b) ). This means that, as determined by the institution, 6 semester hours for an academic term could be sufficient for half-time enrollment, and would suffice to demonstrate community engagement under § 435.552(a)(4).

However, if an individual's institution determines that 6 credit/semester hours is insufficient for half-time enrollment, a State would use our standard to convert that 6 credit/semester hours to monthly hours of educational activity. Under our standard, 6 credit hours converts to 77.94 hours of monthly activity for community engagement (6 credit hours × 3 × 4.33 = 77.94), which is close to, but slightly less than, the 80 hours of activity needed to demonstrate community engagement for a month. This would be an appropriate outcome for a student with a less than half-time course load. We therefore believe that our standard is reasonable and is a fair measurement of time spent on instruction and independent study hours. This standard applies to all educational programs that use credit hours included in the definition at § 435.552(b). We considered adopting a different standard for high school and high school equivalency programs. However, we believe doing so would introduce additional administrative complexity without meaningful benefits for States or individuals. High school and high school equivalency students are developing academic skills for independent learning, and counting the hours they need to do so towards their community engagement hours is consistent with the purpose of the community engagement requirement.

To summarize the standard introduced in this IFC, in cases where the educational institution considers 6 credit/semester hours or fewer to be less than half-time enrollment, multiplying the number of credit hours by 3 to provide the weekly number of hours of educational activity, and then by 4.33 to determine an average monthly number produces the following:

For educational programs that do not use credit hours, if an individual is enrolled less than half-time, then the hours spent attending class and participating in educational activities will count towards meeting the requirement. For example, 1 hour of instruction will count as 1 hour of activity, 2 hours of hands-on training will count as 2 hours of activity, 3 hours of lab work will count as 3 hours of activity, 4 hours of clinical activity will count as 4 hours of activity, and so forth. We believe that this standard will primarily apply to educational programs that train individuals for industry certifications and require individuals to learn and practice technical skills, such as welding, phlebotomy, cosmetology, and precision machining. We decided upon this standard because these types of educational programs generally require a specific number of training hours for certification, so the time spent training is an appropriate way to count the educational program hours. Also, SNAP and TANF use similar standards under their respective work requirements. [ 37 ] SNAP's time limit work requirements specify at 7 CFR 273.24(a)(1) that fulfilling the work requirement can mean participating in and complying with the requirements of a work program for 20 hours per week. A work program at 7 CFR 273.24(a)(3) includes an employment and training program under 7 CFR 273.7(e) , which includes allowable educational program activities such as courses or programs of study. According to 7 CFR 273.7(e)(4)(i) , the time spent in an employment and training program component is determined by the State agency. States can specify participation hours in their FNS SNAP E&T State Plan, for example specifying for an educational component that participants engage in a 5-day training, for 4 hours per day. [ 38 ]

TANF's definitions at 45 CFR 261.2(i) through (l) include hours spent participating in vocational educational training, job skills training directly related to employment, education directly related to employment, and satisfactory attendance at a secondary school or course of study leading to a certificate of general equivalence. For TANF, States submit a Work Verification Plan detailing how they verify and document work participation hours and activities. TANF's Work Verification Plan Guide [ 39 ] also includes examples of work activity descriptions that would be approved for each countable work activity. For example, for vocational educational training, the ( printed page 33360) Work Verification Plan Guide specifies that “Actual hours spent in class as well as time spent performing clinical requirements, lab work or other ancillary activities required for approved vocational educational training programs are considered to be a part of the primary activity for which it is required and is countable.” [ 40 ]

To be clear, when individuals are enrolled less than half-time in an educational program that uses credit hours, States should apply the credit hour standard. However, if the educational program does not use credit hours, then the hours spent attending class and participating in educational activities count towards meeting community engagement. We considered having States convert attendance and participation into credit hours so that there would only be one way to count hours for less than half-time enrollment. However, this would be more burdensome for States, with little meaningful difference for individuals. We welcome comments on any other reasonable approaches.