Prerequisites for TAP Eligibility at BPSS Licensed Schools

Number: 
52-0703
Date Issued: 
07/03/2018

For admission into a licensed private career school, the requirements are set forth in Education Law § 5002; however, eligibility for NYS Tuition Assistance Program funds has additional requirements above those set for admission.  Those requirements are set forth in Education Law § 661.

This guideline sets forth prerequisites for TAP-eligible programs at BPSS schools.

Under Section § 661 of the Education Law, as amended by Chapter 57 of the Laws of 2007, a student seeking Tuition Assistance Program (TAP) aid and other State financial aid for the first time, beginning with the 2007-2008 academic year and thereafter, must pass a federally approved Ability-To-Benefit (ATB) test identified by the Board of Regents if the student does not possess a U.S. high school diploma or its recognized equivalent.

Policy Guideline 41-1115 describes the various types of high school diplomas for use in admission to a school licensed by BPSS.  For the purposes of TAP, there are specific restrictions on high school diplomas and equivalency:  

  • A New York resident student without a valid high school diploma must hold a high school equivalency diploma as identified in 8 NYCRR § 100.7 or § 100.8.  Or a similar high school equivalency from another state, if the student was a former resident of that state.
  • The Board of Regents does not approve correspondence study, including on-line, as equivalent to a high school diploma for New York residents. Therefore, the acquisition of an on-line high school diploma is only an option for those students who are residents of the state where such on-line high school is recognized by that state as a valid high school certificate of graduation at the time that they received the diploma. 
  • A superintendent’s letter of substantial equivalency is not a certificate of graduation or a diploma, nor is it recognized in the Commissioner’s regulations as a recognized equivalency. 
  • It is important to note that the formerly offered IEP Diploma has been replaced by the Skills and Achievement Commencement Credential and the Career Development and Occupational Studies Commencement Credential (CDOS). These credentials are not diplomas but are rather an exit credential that does not carry with it the status of a Local Diploma or recognized equivalency. 
  • Finally, a foreign high school diploma is not recognized as acceptable for TAP purposes.

For the provision of the Ability to Benefit test (ATB):

In 2015, the Board of Regents clarified the list of tests and passing scores approved for licensed career schools.

When submitting curriculum for TAP-approval with BPSS form 30A, please note:

  1. Correct Length and Subject Matter:
    When business and trade schools were licensed separately, TAP was restricted to business schools. The two categories were merged in 2012 as Licensed Private Career Schools, but that distinction still exists for TAP. For BPSS-regulated schools, a curriculum can only be approved for TAP-eligibility on if it consists mainly of business/office courses, has a length of at least 1,440 clock hours, and is taught at least 25 hours/week.
     
  2. Correct Choice of ATB Test, incl. for Foreign Holders of HSD, for TAP Funding:
    The Regents’ approved the following in October 2015:
    • WONDERLIC BASIC SKILLS TEST with federal scores 200 verbal/210 quantitative for holders of verified* high school diplomas;
    • WONDERLIC BASIC SKILLS TEST with scores of 248 verbal/254 for students without high school diploma
    • ASSET
    • COMPASS
    • CELSA for combined ESL/Vocational Programs only.

      While the Regents’ did not specify the scores for Asset, Compass and Celsa, it was implicit that the minimum scores were the former federal scores for Title IV. As ACT, Inc., the publisher of ASSET and COMPASS, discontinued these tests effective 12/31/2016, they cannot be used for TAP as “publisher’s instructions” are not available any longer. The federal score for CELSA is 96 (scaled).

      *The student provides the school a copy of the foreign high school diploma with a translation. Both the copy and the translation must be notarized by a public notary in the United States, and the copy of the diploma and the translation must be maintained in the student file.
       

  3. Academically adequate Entrance Requirements for that program:

    The passing scores set by the Regents’ on these ATB tests are for funding purposes only, they are not necessarily approvable as academic entrance requirements for your program. A Wonderlic Basic Skills Test score in English and Math of 200/210 is equivalent to 7th grade, for example, while CELSA is an ESL test, requiring further evidence of that the student has the academic prerequisites to successfully complete a business curriculum. A school might raise the scores to ensure high-school level preparation if the ATB test is used both for ATB purposes and for TAP qualifying purposes. A combined ESL/Vocational program using CELSA as the qualifying ATB test for TAP must include the math component of one of the approved ATB tests, including the discontinued ASSET or COMPASS, given either at the beginning or at the end of the ESL component. That math test is a “programmatic requirement,” not a TAP-qualifying test, to avoid complications from having two separate tests for TAP giving at separate intervals. Depending on the subject matter, BPSS might still require a high school diploma as academic prerequisite, whether domestic or foreign, with the ATB test taken by the foreign high school diploma holders solely to qualify for TAP.

    For matters concerning TAP that are not under BPSS oversight, contact the Higher Education Services Corporation (HESC) and tappolicy@hesc.org or the NYSED Office of Higher Education.  For the independent administration of the ATB test, see §145-2.15 of the Commissioner’s Regulations, amended in March 2009.

If you have any curriculum-related questions, contact the BPSS curriculum unit at  BPSScurriculum@nysed.gov