FY 2025_FIPSE-SP Program_FAQs FINAL 12.1.25.pdf

Fund for the Improvement of Postsecondary Education (FIPSE) Special Projects

(84.116J)

Frequently Asked Questions (FAQs)

1. Overview & Eligibility: Q1-Q14

2. Absolute & Competitive Preference Priorities: Q15-Q54

3. Funding: Q55-Q59

4. Subawards & Partners: Q60-Q71

5. Application Logistics: Q72-Q94

6. Evaluation & Performance Reporting: Q95-Q99

7. Allowable Costs & Activities: Q100-Q112

8. Technical Assistance: Q113-Q129

9. Open Licensing: Q130-Q141

Disclaimer: Please note the Notice Inviting Applications (NIA) in the Federal Register is the official application submission guide. These FAQs provide additional technical assistance only.

SECTION 1: OVERVIEW & ELIGIBILITY

1. What is the purpose of the FIPSE – SP program?

The purpose of the FIPSE – SP program is to provide grants to institutions of higher education (IHEs), combinations of such institutions, and other public and private nonprofit institutions and agencies, as the Secretary deems necessary, to support innovative projects concerning one or more areas of national need identified by the Secretary. This competition focuses on supporting four (4) areas of national need – 1) expanding the understanding and use of Artificial Intelligence (AI) technology in postsecondary education, 2) promoting civil discourse on college and university campuses, 3) promoting accreditation reform, and 4) supporting capacity-building for high-quality short-term programs.

In order to support these four (4) crucial needs, this competition includes seven (7) Absolute priorities under which applicants can apply: two (2) priorities dedicated to advancing the https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects understanding and use of AI in education (Absolute Priorities 1 and 2), one (1) priority dedicated to promoting civil discourse on college and university campuses (Absolute Priority 3), two (2) priorities promoting accreditation reform (Absolute Priorities 4 and 5), and two (2) priorities for capacity-building for high-quality short-term programs (Absolute Priority 6 and 7).

The competition also includes two (2) Competitive Preference Priorities in the area of promoting civil discourse on college and university campuses. The Department intends to award $50 million to advance AI in Education, $60 million to promote civil discourse on college and university campuses, $7 million to support accreditation reform, and $50 million to develop high-quality short-term programs.

2. What is the deadline to submit an application for the FY 2025 competition?

The deadline for the FY 2025 competition is 11:59:59 p.m. ET on December 3, 2025.

3. Who is eligible to apply? Are there limitations on eligible applicant submissions?

Institutions of higher education (as defined in section 101 of the Higher Education Act of 1965, as amended (HEA)), consortia of such institutions, and other public and private nonprofit institutions and agencies including State higher education agencies as defined in 20 U.S.C.

1003(22).

The eligible entity may apply to all four (4) areas of national need as the lead applicant but must submit a separate grant application for each area of national need. The eligible entity may submit only one (1) grant application under an area of national need as the lead applicant. For areas of national need with more than one Absolute Priority, the applicant must select one of the two Absolute Priorities that will be addressed in the application narrative. We understand that a particular project may include elements that connect to both Absolute Priorities within an area of national need. Therefore, applicants are not precluded from incorporating elements from both Absolute Priorities

Please see the following table for additional clarification/guidance:

Area of National Need

Absolute Priorities

The eligible entity may apply to all four (4) areas of national need as the lead applicant but must submit a separate grant application for each area of national need.

Estimated Funding

Maximum Budget https://www.govinfo.gov/content/pkg/COMPS-765/pdf/COMPS-765.pdf https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf

(1) Advancing the Understanding of and Use of Artificial Intelligence (AI) Technology in Postsecondary Education

AP1 and AP2 One application AP 1: $25 million

AP 2: $25

million

$4 million for AP1

$4 million for AP2

(2) Promoting Civil Discourse on College and University Campuses, AP3 + CPP1 and CPP2

One application AP 3: $60 million

$4 million max

(3) Promoting Accreditation Reform

AP4 and AP5 One application AP 4: $3.5 million

AP 5: $3.5

million

$1 million for AP 4

$1 million for AP 5

(4) Supporting Capacity-Building for High-Quality Short-Term Programs.

AP6 and AP7 One application AP 6: $25 million

AP 7: $25

million

$4 million for AP6

$4 million for AP7

4. What are the definitions for the entities listed in the eligibility section?

As noted in the NIA, the following entities are defined accordingly:

a. Institution of Higher Education (IHE) – as defined in section 101 of HEA.

b. Other public and private nonprofit institutions and agencies and State

Higher Education Agency (SHEA) - as defined in 20 U.S.C. 1003(22).

i. State higher education agency means the officer or agency primarily responsible for the State supervision of higher education.

ii. The term ‘‘nonprofit’’ as applied to a school, agency, organization, or institution means a school, agency, organization, or institution owned and operated by one or more nonprofit corporations or associations, no part of the net earnings of which inures, or may lawfully inure, to the benefit of any private shareholder or individual.

https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects https://www.govinfo.gov/content/pkg/COMPS-765/pdf/COMPS-765.pdf https://www.govinfo.gov/link/uscode/20/1003

5. For nonprofit institutions and agencies, what do they have to include in their application to demonstrate eligibility?

An applicant that is a nonprofit organization may, under 34 CFR 75.51, demonstrate its nonprofit status by providing:

a. Proof that the Internal Revenue Service currently recognizes the applicant as an organization to which contributions are tax deductible under section 501(c)(3) of the Internal Revenue Code.

b. A statement from a state taxing body or the State attorney general certifying that the organization is a nonprofit organization operating within the State and that no part of its net earnings may lawfully benefit any private shareholder or individual.

c. A certified copy of the applicant's certificate of incorporation or similar document if it clearly establishes the nonprofit status of the applicant; or

d. Any item described above if that item applies to a State or national parent organization, together with a statement by the State or parent organization that the applicant is a local nonprofit affiliate.

6. How should we demonstrate the type of entity of a lead applicant and/or partner institution/organization as it applies to the eligibility criteria?

Applicants should provide ample documentation regarding their entity type. For example, an applicant that is a nonprofit organization may, under 34 CFR 75.51, demonstrate its nonprofit status by providing:

(1) proof that the Internal Revenue Service currently recognizes the applicant as an organization to which contributions are tax deductible under section 501(c)(3) of the Internal Revenue Code;

(2) a statement from a State taxing body or the State attorney general certifying that the organization is a nonprofit organization operating within the State and that no part of its net earnings may lawfully benefit any private shareholder or individual;

(3) a certified copy of the applicant's certificate of incorporation or similar document if it clearly establishes the nonprofit status of the applicant; or

(4) any item described above if that item applies to a State or national parent organization, together with a statement by the State or parent organization that the applicant is a local nonprofit affiliate.

https://www.ecfr.gov/current/title-34/section-75.51 https://www.ecfr.gov/current/title-34/section-75.51

Note: If it is not clear that an applicant meets the eligibility criteria, the application may be flagged as ineligible.

7. What documents do state agencies need to submit to prove their eligibility?

While there is no specific documentation noted in the NIA for state agencies to demonstrate eligibility, applicants should provide ample documentation regarding their entity type.

Note: If it is not clear that an applicant meets the eligibility criteria, the application may be flagged as ineligible.

8. Where in the application should proof of nonprofit status, as referenced in the NIA, be included?

Documents related to evidence of nonprofit status should be included in the “Other Attachments” section. In addition, applicants should reference their nonprofit status in the abstract and the Significance section, and they should indicate that the corresponding documents are located in the “Other Attachments” section.

9. Can an institution/ organization submit multiple applications? If we submit an application as the lead applicant, can we also be a partner/subgrantee on another application?

Yes. An eligible entity may submit an application to each of the four (4) areas of national need as the lead applicant. However, an eligible entity may submit only one (1) grant application under an area of national need as the lead applicant (and must clearly identify which absolute priority the application is addressing). An entity can be included as a partner in multiple applications.

10. Can an institution apply to partner with a for-profit organization?

No. Under 34 CFR 75.127, only eligible parties may apply in partnership under a particular competition. Because for-profit organizations are not eligible entities under 20 U.S.C. § 1138 (a), institutions may not apply to partner with them.

11. Are K–12 public school districts eligible to apply for funding under the current FIPSE- SP program, or to participate as lead applicants in partnership with higher education institutions?

https://www.ecfr.gov/current/title-34/section-75.127 https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapVII-partB-sec1138.pdf

Yes, as long as the applicant demonstrates it meets the eligibility requirements for “public or private nonprofit institutions or agencies”.

12. Can system offices apply on behalf of their institutions? For example, could the “State Board of Community and Technical Colleges,” an administrative body representing 20 community and technical colleges be eligible to lead a project?

If the system is a State higher education agency, then they could serve as the lead applicant. If the system is not a State higher education agency, then one of their eligible IHEs should be designated as the lead applicant.

13. Can a university or college system (and all the affiliated colleges in the system) be considered a single IHE?

If the system is a State higher education agency, then they could serve as the lead applicant. If the system is not a State higher education agency but rather is a group of multiple affiliated colleges and universities that are managed by a single governing body, such as a board of regents or trustees, then one of their eligible IHEs should be designated as the lead applicant.

14. Do institutions of higher education need to accept Pell Grant funds for the specific program they are applying for, or do they just need to meet Pell eligibility?

For the FY 2025 FIPSE-SP competition, institutions of higher education (IHEs) (as defined in section 101 of the HEA), also meets the requirements of participation in Title IV funds – which includes Pell funding. Thus, IHEs must be eligible to participate in and accept Title IV funding.

SECTION 2: ABSOLUTE & COMPETITIVE PREFERENCE PRIORITIES

15. What are the funding priorities of the FY 2025 competition?

The notice contains seven (7) Absolute priorities under which applicants can apply and are outlined below. Additionally, within Absolute Priority 3 there are two (2) Competitive Preference Priorities (CPPs). Under 34 CFR 75.105(c)(2)(i), we will award an additional ten (10) points to an application that meets each of these Competitive Preference Priorities. Applicants may receive Competitive Preference Priority points for both CPP 1 and CPP 2. The Priorities are as follows:

(1) Advancing the Understanding and Use of Artificial Intelligence (AI) in Education

a. Absolute Priority 1: Advancing Artificial Intelligence to Improve Educational

Outcomes of Postsecondary Students https://www.ecfr.gov/current/title-34/section-75.105#p-75.105(c)(2)(i)

b. Absolute Priority 2: Ensuring Future Educators and Students Have Foundational Exposure to AI and Computer Science

(2) Promoting Civil Discourse on College and University Campuses

a. Absolute Priority 3: Promoting Civil Discourse on College and University

Campuses

i. Competitive Preference Priority 1 (0 or 10 points): Civic Institutes at

Institutions of Higher Education

ii. Competitive Preference Priority 2 (0 or 10 points): Non-IHE Nonprofit

Organizations That Educate Students to Promote Freedom and Engage in Civil Discourse

(3) Promoting Accreditation Reform

a. Absolute Priority 4: Supporting Institutions in Changing Accrediting Agencies

b. Absolute Priority 5: Supporting the Creation of New Accrediting Agencies

(4) Capacity-Building for High-Quality Short-Term Programs

a. Absolute Priority 6: Creation of New High-Quality Short-Term Programs

b. Absolute Priority 7: Expansion of Existing High-Quality Short-Term Programs

16. What is the difference between Absolute and Competitive Preference Priorities?

In order to be considered for funding, each application must address one (1) of the Absolute Priorities under an area of national need. An applicant can choose whether or not to address a Competitive Preference Priority.

For the Competitive Preference Priorities (CPPs) under Absolute Priority 3 (Promoting Civil Discourse on College and University Campuses), applications that successfully address one or both CPPs may receive an additional ten (10) points for each of these Competitive Preference Priorities. Applicants may receive Competitive Preference Priority points for both CPP 1 and CPP 2. Please refer to the Notice Inviting Applications (NIA) for more details.

17. Must an institution/ organization meet both Absolute and Competitive Preference Priorities?

While Competitive Preference Priorities are optional to respond to, only applications that address one (1) of the Absolute priorities will be considered for funding.

https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects

18. Are the Absolute and Competitive Preference Priorities included as part of the recommended page limit?

Yes. The recommended page limit is 35 pages. Responses to the Absolute Priorities and Competitive Preference Priorities, if applicable, should be included in this section.

Responses to the Competitive Preference Priorities under Absolute Priority 3 should be clearly marked as Competitive Preference Priority 1 and/or Competitive Preference Priority 2.

19. Can an institution apply to two different areas of national need using the same focus area, for example, can an AI project be submitted under both the AI priority area and the high-quality short-term programs?

An eligible entity may submit an application to each of the four (4) areas of national need as the lead applicant. However, an eligible entity may submit only one (1) grant application under an area of national need as the lead applicant (and must clearly identify which absolute priority the application is addressing). For areas of national need with more than one Absolute Priority, the applicant must select one of the two Absolute Priorities that will be addressed in the application narrative. We understand that a particular project may include elements that connect to both Absolute Priorities within an area of national need. Therefore, applicants are not precluded from incorporating elements from both Absolute Priorities.

For each application, it is the applicant's responsibility to sufficiently address the requirements of the absolute priority they are responding to. Applicants should address each of the selection criteria as the project pertains to the area of national need and Absolute Priority the applicant is responding to, and if applicable, the responses to one or both Competitive Preference Priorities in Absolute Priority 3, as all applications will be evaluated based on the selection criteria.

20. For each priority, is there a preference given to particular type of applicants?

No, we do not give preference to a particular type of applicant. An eligible applicant is an institutions of higher education (as defined in section 101 of the Higher Education Act of 1965, as amended (HEA)), consortia of such institutions, and other public and private nonprofit institutions and agencies including State higher education agencies as defined in 20 U.S.C.

1003(22).

21. If one selected Absolute Priority 1, are they able to select either (a) or (b) under this priority? If yes, if they select (b) are they required to address (I), (ii), and (iii) or can they simply focus on (b) (ii) (iii) https://www.govinfo.gov/content/pkg/COMPS-765/pdf/COMPS-765.pdf https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf

Yes, an applicant applying under Absolute Priority 1 may opt to address 1(a) only, 1(b) only, or both. For priorities that state “one or more of the following,” and include subparts, you must address at least one of the subparts, but you may also opt to address a combination of them or all of them.

22. We see under Absolute Priority 1 that language requests “projects or proposals to improve academic instruction and student learning, including efforts designed to assess learning gains made by postsecondary students.”

Then, section b describes how projects can partner with state or local education agencies. Does this mean a project focused on middle school students and their teachers would qualify for this call? If so, do we need to specify how improving middle school literacy is related to later postsecondary success?

AP1 must include efforts designed to assess the learning gains made by postsecondary students, but a proposal does not need to be only focused on postsecondary students. It is the applicant’s responsibility to adequately address how their project will meet the absolute priority through its services, activities, and target audience.

23. Can an applicant address Absolute Priority 2 by partnering with a school instead of a LEA or SEA?

An application under Absolute Priority 2 must “leverage AI to improve teacher preparation by doing one of subparts (a) through (g). While the language in subpart or more of the following that addresses subparts (f) and (g) explicitly mention LEAs/SEAs, not an individual school, a proposed project that includes a partnership with a single school could still meet the requirements of Absolute Priority 2 by addressing one or more of the other subparts.

24. For the purposes of AP1(b), is partnering with an SEA/LEA a requirement or can the project only focus on the post-secondary level?

If you aren’t partnering with an SEA/LEA, then you shouldn’t attempt to address 1b. An applicant applying for Absolute Priority 1 may opt to address 1(a) only, 1(b) only, or both. For the subparts, you must address at least one of them and you may also opt to address a combination of them or all of them. So, clearly label if you’re addressing Absolute Priority 1(a), or Absolute Priority 1(b), or Absolute Priority 1(a) (b), and for the subparts, please identify which one(s) you will address – (i) or maybe you will address (ii) & (iii), etc.

25. Would a focus on developing and delivering a Master of Science program in Computer Science be considered an appropriate response to Absolute Priority 2 (a)?

Under Absolute Priority 2(a), an applicant may propose a project that leads to an AI and computer science credential in rural communities. Credentials can include master or professional degrees.

26. In Absolute Priority 2(a), it notes “Deliver AI and computer science credentials in rural communities”. How is rural community defined in this competition?

This competition does not include a definition for “rural community”; therefore, applicants have flexibility to define “rural community” in their application. Applicants should clearly demonstrate how they are defining “rural community” and the target population to be served, specifically as it relates to Absolute Priority 2 – Ensuring Future Educators and Students Have Foundational Exposure to AI and Computer Science.

Note: For assistance with identifying rural communities, applicants may retrieve locale codes from the following NCES search tools. This is included as a resource to assist applicants;

however, it is not required for applicants to provide the NCES locale codes in order to meet the requirements of Absolute Priority 2.

a. NCES School District search tool (https://nces.ed.gov/ccd/districtsearch/), where LEAs can be looked up individually to retrieve locale codes

b. Public School search tool (https://nces.ed.gov/ccd/schoolsearch/), where individual schools can be looked up to retrieve locale codes.

c. NCES College Navigator search tool (https://nces.ed.gov/collegenavigator/), where IHEs can be looked up individually to determine the campus setting.

27. In Absolute Priority 3, how are “civil discourse”, “freedom”, “civic thought”, “constitutional studies”, “American history”, and “economic liberty” defined?

These terms are not defined in the NIA. However, the Department encourages applicants to refer to the text of the absolute priority and the background section for additional guidance on the types of projects the Department is seeking to support.

28. In Absolute Priority 3, what does the term “academic unit” mean?

This term means: (1) colleges, schools, and departments of civics, history, ethics, government, etc. at universities and colleges; (2) independent centers or offices at colleges and universities primarily focused on those topics; and (3) social studies, history, government programs, etc.

within a university’s school, college, or department of education."

https://nces.ed.gov/ccd/districtsearch/ https://nces.ed.gov/ccd/schoolsearch/ https://nces.ed.gov/collegenavigator/ https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects

29. In Competitive Preference Priority 1 (CPP 1) in Absolute Priority 3, how can an applicant show that independent academic units “demonstrate a sustained commitment to robust civil discourse, the liberal arts, and the study of American history and politics through primary documents”?

An applicant may provide this evidence through the IHE’s offerings in degree programs (including interdisciplinary degrees with related departments), courses addressing relevant content areas, research and expertise of related faculty, and educational and research events (seminars, symposia, workshops, etc.) pertaining to the relevant areas of the priorities.

30. For Absolute Priority 3 and CPP 1, if an applicant has an institute that focuses on one, but not all the specified activities (i.e. civic thought, constitutional studies, American history, and economic liberty) should they describe it under CPP1?

Under each Absolute Priority, applicants must meet the priority as they are described (34 CFR 75.105(c)(3)). For example, Absolute Priority 3, Promoting Civil Discourse on College and University Campuses, the proposed project must be designed to promote civil discourse on college and university campuses using one or more of the listed activities and focused areas.

31. Are institutions that have not yet established separate centers or institutes for civil discourse ineligible?

The inclusion of civic institutes at IHEs in CPP1 is optional for an applicant to respond to, therefore, applicants do not need to have established a civic institute to meet the requirements of Absolute Priority 3.

Note: It is up to the applicant to sufficiently address the requirements of Absolute Priority 3, that is projects that are designed to promote civil discourse on college and university campuses through activities such as seminars, speaker series, conferences, debates, workshops training events, and other focused learning opportunities that include a range of views and embrace dialogue and understanding. These projects may include visiting faculty specifically supporting the development and delivery of these activities and contributing to the viewpoint diversity of the broader campus intellectual environment.

32. In Competitive Preference Priority 2 (CPP 2) in Absolute Priority 3, can the non-IHE nonprofit organization be part of the lead applicant’s IHE?

No, the non-IHE nonprofit organization must be independent of the IHE.

Note: As a reminder, to meet the requirements of CPP 2 non-IHE nonprofit organizations are private nonprofit organizations that do not meet the HEA definition of an institution of higher https://www.ecfr.gov/current/title-34/part-75/section-75.105#p-75.105(c)(3) https://www.ecfr.gov/current/title-34/part-75/section-75.105#p-75.105(c)(3) education and that educate students to promote freedom and engage in civil discourse.

Furthermore, these entities must demonstrate experience working with higher education institutions on matters of civil discourse.

33. In CPP 2 in Absolute Priority 3, how can an applicant show that a non-IHE nonprofit organization has “demonstrate[d] experience working with higher education institutions on matters of civil discourse”?

A non-profit organization may provide to the applicant evidence of “demonstrated experience” by providing documentation related to services, events, and products provided to or in partnership with college and universities relative to the exchange of information or debate of ideas on matters related to the public good or civic governance.

34. Do AP3 projects have to provide academic credit?

No. This priority supports projects that are designed to promote civil discourse on college and university campuses through activities such as seminars, speaker series, conferences, debates, workshop training events, visiting professorships and other focused learning opportunities that include and promote a range of views and embrace dialogue and understanding.

35. For Absolute Priority 4, can IHEs propose projects to change or add accrediting agencies that are not yet recognized by the Department?

Absolute Priority 4 and the NIA do not define or limit the term ‘accrediting agency’ to a ‘nationally recognized accrediting agency’ as otherwise defined under 34 CFR 600.2. Because this term is undefined, the Department will accept projects under Absolute Priority 4 that propose to change or add accrediting agencies that are not yet recognized by the Department.

Note: Adding or changing accrediting agencies may impact institutional eligibility under Title IV and recommends that institutions of higher education contact aslrecordsmanager@ed.gov for questions of institutional eligibility.

36. What are the requirements/process for notifying the Department if an applicant proposes changing accrediting agencies?

Please review the “Changes to the Approval Process for Changing Accrediting Agencies” in the Dear Colleague Letter published on May 1, 2025: https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2025-04-30/changes-approval-process-changing-accrediting-agencies.

https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects https://www.ecfr.gov/current/title-34/section-600.2 mailto:aslrecordsmanager@ed.gov https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2025-04-30/changes-approval-process-changing-accrediting-agencies https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2025-04-30/changes-approval-process-changing-accrediting-agencies https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2025-04-30/changes-approval-process-changing-accrediting-agencies

For additional questions about the Dear Colleague Letter, please email us at FIPSE-SP@ed.gov.

37. In terms of Absolute Priority 5, Supporting the Creation of New Accrediting Agencies, is it correct that new programmatic accreditors are eligible to apply, in addition to new institutional accrediting agencies?

Yes, new programmatic accreditors are eligible to apply as long as the lead applicant meets the eligibility criteria for this competition:

• Institutions of higher education (as defined in section 101 of the HEA),

• Consortia of such institutions

• Other public and private nonprofit institutions and agencies including State higher education agencies as defined in 20 U.S.C. 1003(22).

38. For accreditation reform, is there a preference for schools that have not yet changed (or requested to change) accreditors? Or is this also open to public universities in the process of changing accreditors?

Absolute Priority 4 and 5 addresses changing current accrediting agencies or creating new accrediting agencies. The Department will accept projects under Absolute Priority 4 that propose to change or add an accrediting agency that has not been currently recognized by the Department. Additional information and assistance can be obtained by aslrecordsmanager@ed.gov.

39. Is it possible to focus the grant on specific job sectors in Absolute Priority 6 and 7

(National Need Area #4)?

Yes, it is possible to focus the project on specific job sectors, assuming they meet and align with the definition of high-quality, short-term programs as defined by the One Big Beautiful Bill Act (OBBBA) and are in-demand industry sectors as defined by Workforce Innovation and Opportunity Act (WIOA).

Note: High-quality, short-terms programs as defined in the eligibility requirements in the Workforce Pell Grants program in Section 83002(b) of the OBBBA, including program length requirements and alignment with high-skill, high-wage, or in-demand industry sectors or occupations.

Note: In-demand industry sectors or occupations, as defined in section 3(23) of the WIOA, means (i) an industry sector that has a substantial current or potential impact (including through jobs that lead to economic self-sufficiency and opportunities for advancement) on the State, regional, or local economy, as appropriate, and that contributes to the growth or stability of mailto:FIPSE-SP@ed.gov https://www.govinfo.gov/content/pkg/COMPS-765/pdf/COMPS-765.pdf https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf mailto:aslrecordsmanager@ed.gov https://www.congress.gov/bill/119th-congress/house-bill/1/text https://www.govinfo.gov/content/pkg/COMPS-11135/pdf/COMPS-11135.pdf https://www.govinfo.gov/content/pkg/COMPS-11135/pdf/COMPS-11135.pdf other supporting businesses, or the growth of other industry sectors; or (ii) an occupation that currently has or is projected to have a number of positions (including positions that lead to economic self-sufficiency and opportunities for advancement) in an industry sector so as to have a significant impact on the State, regional, or local economy, as appropriate.

40. In Absolute Priority 6 and 7, what are the program eligibility requirements for Workforce Pell Grants in the One Big Beautiful Bill Act (OBBBA)?

Section 83002(b) of the OBBBA lists the program eligibility requirements for Workforce Pell Grants. The text of the bill is located here: https://www.congress.gov/bill/119th-congress/house-bill/1/text.

According to Section 832002 (b), an eligible Workforce Pell Grant program is a program that must be at least 150 clock hours of instruction, but less than 600 clock hours of instruction (or an equivalent number of credit hours), offered during a minimum of eight weeks but less than 15 weeks, and is not offered as a correspondence course. In addition, an eligible program must be approved by the State Governor in accordance with the requirements in Section 83002(b)(2)(iii) of the OBBBA.

41. For Priorities #6 and #7, we're wondering if the short-term programming can be as long as 15 weeks, or if it has to be less than 15 weeks in length. Can you please clarify?

According to Section 832002 (b), an eligible Workforce Pell Grant program is a program that must be at least 150 clock hours of instruction, but less than 600 clock hours of instruction (or an equivalent number of credit hours), offered during a minimum of eight weeks but less than 15 weeks, and is not offered as a correspondence course. In addition, an eligible program must be approved by the State Governor in accordance with the requirements in Section 83002(b)(2)(iii) of the OBBBA.

42. Our program is currently not compliant with the Workforce Pell Eligibility requirements, specifically in that it is over the 15-week requirement. Are we eligible to apply to AP7 if our existing program does not yet meet the Workforce Pell Eligibility requirements, but we intend to revise it to be brought into compliance? Or is it more suitable to apply to priority 6, and focus only on new programs?

AP7 seems most appropriate for your situation since the priority permits reforms to existing programs to meet Workforce Pell Grants eligibility requirements in the One Big Beautiful Bill Act. Please note that we understand that a particular project may include elements that connect to https://www.congress.gov/bill/119th-congress/house-bill/1/text https://www.congress.gov/bill/119th-congress/house-bill/1/text both Absolute Priorities within an area of national need. Therefore, applicants are not precluded from incorporating elements from both Absolute Priorities.

43. Who qualifies as an eligible student for a Workforce Pell Grant under OBBBA?

To meet basic eligibility for a Workforce Pell Grant under OBBBA, a student must:

• Meet normal Pell eligibility (e.g., financial need, undergrad level).

• Be enrolled in an eligible workforce program—short‑term, non‑degree, accredited.

• Not simultaneously receiving a traditional Pell Grant or a TEACH Grant.

The Department will provide active communication and technical assistance for grantees selected funding under this program, to ensure that such grantees are made aware of any updates to Workforce Pell Grant student eligibility as a result of negotiated rulemaking.

44. Would modifying an existing short-term program to become Workforce Pell eligible be a creation or an expansion?

Modifying an existing program would be an expansion. The language of AP7 notes that reforms to existing programs are included in this effort.

45. For Priority 6, how should we demonstrate industry engagement? Is a letter of support required, or is it sufficient to describe the partnership in the narrative?

Applicants are strongly advised to provide a letter of support for all partners, contractors, and/or subgrantees. Applicants should clearly identify all partners, contractors, and subgrantees in the abstract, project narrative, and budget narrative, if applicable. Applicants should include services to be performed and products to be provided, along with the corresponding costs.

46. Because we are writing one application for Priority 6 and Priority 7, do we need separate budgets for both, or will one budget suffice?

If you are incorporating elements from both priorities within an area of national need, you only need to provide one budget. Applicants may not request more than the maximum amount of funding outlined in the NIA for the area of national need you are responding to – in this case $4,000,000 total for National Need Area #4 (Absolute Priority 6 or 7). Applicants should upload a detailed supporting Budget Narrative explaining the proposed costs for each year of the performance period. Total costs per year should align with the costs stated on the ED-524 Budget Form.

47. Are fully online programs eligible for Absolute Priority #6?

A fully online program that meets all other eligibility requirements for the Workforce Pell Grant Program may be considered an eligible program where such a program is not offered as a “correspondence course” under 34 CFR 600.2. For reference, “correspondence courses” are defined under 34 CFR 600.2 as follows:

(1) A course provided by an institution under which the institution provides instructional materials, by mail or electronic transmission, including examinations on the materials, to students who are separated from the instructors. Interaction between instructors and students in a correspondence course is limited, is not regular and substantive, and is primarily initiated by the student.

(2) If a course is part correspondence and part residential training, the Secretary considers the course to be a correspondence course.

(3) A correspondence course is not distance education.

The prohibition in the One Big Beautiful Bill Act preventing Workforce Pell Grant Programs from being offered as a “correspondence course” does not limit otherwise eligible online programs from being offered through “distance education.”

48. For Priority 6, would it be allowable for the certificates to target learners who already have a bachelor’s degree, particularly for upskilling or reskilling purposes?

When addressing Absolute Priority 6 the proposed activity must be designed to ensure that it meets the eligibility requirements of the Workforce Pell Grants program in Section 8300(b) of the One Big Beautiful Bill Act, including program length requirements and alignment with high-skill, high-wage, or in-demand industry sectors or occupations.

49. The slides in the informational webinar indicate that only Absolute Priority #7 programs have to meet Workforce Pell Grant eligibility requirements. But in the solicitation, Absolute Priority #6 also has to meet Workforce Pell Grant eligibility requirements. Does Absolute Priority #6 need to meet Workforce Pell Grant eligibility requirements?

The NIA states, under both AP6 and AP7, that “high-quality short-term programs are defined as programs that meet the eligibility requirements of the Workforce Pell Grant program in Section 83002(b) of the One Big Beautiful Bill Act.”

50. Can you confirm programs that are equal to 15 weeks are eligible for funding under this NOFO?

Eligible Workforce Pell Grant programs consist of “a program of at least 150 clock hours of instruction, but less than 600 clock hours of instruction, or an equivalent number of credit hours, offered by an eligible institution during a minimum of 8 weeks, but less than 15 weeks” means that programs equal to 15 weeks would not be considered an eligible Workforce Pell Grant program.

In the One Big Beautiful Bill Act, there is a One-Year Existence Rule: The legislation requires that any program must be operating for at least one year before the Secretary of Education can approve it for Workforce Pell funds.

You must meet the requirements to access the funding. July 1, 2026, is the effective date on which schools will be able to offer Workforce Pell Grants. So, applicants under these two priorities (AP6 and AP7) will want to describe how their proposed new program, or their proposed expanded/modified program will meet the program eligibility requirements.

51. Under this NOFO, would we be able to access Workforce Pell funding in year 1?

You have to meet the requirements to access the funding. July 1, 2026, is the effective date on which schools will be able to offer Workforce Pell Grants. So, applicants under these two priorities (AP6 and AP7) will want to describe how their proposed new program, or their proposed expanded/modified program will meet the program eligibility requirements.

52. Absolute Priority 3 has 120 available points with 20 CPP points. Will all applications for all priorities be scored on a 120-point scale, or will the number of grants under Priority 3 be capped and applications for the other priorities scored and awarded on a 100-point scale?

The selection criteria for this competition are from 34 CFR 75.210. Applicants should address each of the selection criteria separately for each proposed activity. The selection criteria are worth a total of 100 points. If an applicant is responding to the Competitive Preference Priorities in Absolute Priority 3, a maximum of 10 additional points under each competitive preference priority will be awarded, for a total score of up to 120 points.

If an applicant is responding to Absolute Priority 1, 2, 4, 5, 6, or 7, all application will be evaluated based on the selection criteria as follows.

https://www.ecfr.gov/current/title-34/section-75.210

SELECTION CRITERIA POINT VALUES

(1) Significance Maximum 30 points

(2) Quality of the Project Design Maximum 45 points

(3) Quality of the Management Plan Maximum 10 points

(4) Quality of the Project Evaluation Maximum 15 points

Total Maximum Score Maximum 100 Points

If an applicant is responding to Absolute Priority 3, and the associated Competitive Preference Priorities, all applications will be evaluated based on the selection criteria as follows:

SELECTION CRITERIA POINT VALUES

(1) Significance Maximum 30 points

(2) Quality of the Project Design Maximum 45 points

(3) Quality of the Management Plan Maximum 10 points

(4) Quality of the Project Evaluation Maximum 15 points

Total Maximum Score Maximum 100 Points

Total score for Competitive Preference Priority #1 0 or 10 points

Total score for Competitive Preference Priority #2 0 or 10 points

TOTAL POSSIBLE SCORE PER APPLICATION Maximum 120 Points

53. The NIA says in multiple places, “Applicants should address each of the selection criteria separately for each proposed activity.” Does this mean that we need to talk about every single activity and then explicitly note how it aligns with the selection criterion? If so, what counts as an activity? For example, for student events, do we need to talk about student events in general as an activity, or do we need to separate out each event as an activity?

Applicants should clearly address each Selection Criterion with corresponding responses to the factors (sub criteria) for each criterion. For example, under the Quality of the Project Design Selection Criterion, applicants must provide a separate, detailed response for each of the 3 factors (worth 15 points each) that comprise this criterion. For additional guidance, please review the Pre-Application Webinar and the accompanying slide deck. Regarding activities, each proposed activity should be clearly described, noting its alignment with the pertinent factor of the Selection Criterion(a).

54. How will reviewers weigh research versus evaluation focus in the proposed work? Is one approach or the other preferred?

Reviewers with expertise in areas pertinent to the grant program will evaluate and score applications based on the selection criteria. The selection criteria for this competition are from 34

CFR 75.210.

The Project Narrative is where the applicant provides detailed responses to each selection criterion, as the project pertains to the area of national need and Absolute Priority or Priorities the applicant is responding to, and if applicable, the responses to one or both Competitive Preference Priorities in Absolute Priority 3. The selection criteria are worth a total of 100 points;

the maximum score for each criterion is noted in parentheses. If an applicant responds to the Competitive Preference Priorities in Absolute Priority 3, a maximum of 10 additional points under each competitive preference priority will be awarded, for a total score of up to 120 points.

Note: Please refer to the NIA for a more detailed breakdown of the selection criteria.

SECTION 3: FUNDING

55. Are the stated dollar amounts for each award in the NIA under “II. Award Information” the estimated and maximum amounts per year or for the entire project period?

The estimated and maximum award amounts listed under Section “II. Award Information” of the NIA corresponds to the entire 48-month project period.

56. May an applicant request less than the average award size?

Yes.

57. What does “frontloaded” mean?

The term “frontloaded” means that a funded project will receive all years of funding at the time of award.

https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects

58. What is the performance period for this grant?

Up to 48 months.

59. We noticed that it is anticipated that the average grant award will be $2,000,000. If we write the proposal for $4,000,000, is there a possibility that the award team will approve the grant proposal for a smaller amount and ask us to adjust the budget? Or is it an all-or-nothing approach, and we need to ask for a smaller award amount? We just don't want to potentially penalize our application by asking for the whole $4M.

Does that make sense?

The scope and budget of the project is at the applicant’s discretion. As noted in the NIA, there is a max budget but there is not a minimum budget. Please visit the Frequently Asked Questions and other related resources, which may be found on the FIPSE-SP website, for more information on the program.

SECTION 4: SUBAWARDS & PARTNERS

60. Are subgrants allowable?

Yes, a grantee may award subgrants--to directly carry out project activities--to the following types of entities listed in their grant application: IHEs and public and private nonprofit institutions and agencies including State higher education agencies as defined in 20 U.S.C.

1003(22).

Yes, a grantee may award subgrants to directly carry out project activities ONLY to eligible entities. Please see the eligibility portion of the NIA or FAQ #3 for this list.

61. Do the subgrantees need to be the same entity type as the lead applicant?

No, subgrantees do not need to be the same entity type as the lead applicant. Under 34 CFR 75.708(b) and (c), a grantee under this competition may award subgrants to directly carry out project activities described in its application to the following types of entities: IHEs and public and private nonprofit institutions and agencies including State higher education agencies as defined in 20 U.S.C. 1003(22).

Note: If a subgrantee is a nonprofit organization they must demonstrate its nonprofit status according to the requirements in the eligibility criteria.

https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapI-partA-sec1003.pdf https://www.federalregister.gov/documents/2025/11/12/2025-19843/applications-for-new-awards-fund-for-the-improvement-of-postsecondary-education-special-projects https://www.ecfr.gov/current/title-34/section-75.708#p-75.708(b) https://www.ecfr.gov/current/title-34/section-75.708#p-75.708(b) https://www.ecfr.gov/current/title-34/section-75.708#p-75.708(c) https://www.govinfo.gov/link/uscode/20/1003

62. Are private, for-profit organizations allowed to be a subgrantee? Alternatively, can a private, for-profit organization receive funding as a contractor/consultant as a direct cost line item under our award?

No. A lead applicant can only provide subgrants to eligible entities as explained in the NIA and FAQ #3. Under 34 CFR 75.708(b) and (c), a grantee under this competition may award subgrants to directly carry out project activities described in its application to the following types of entities: IHEs and public and private nonprofit institutions and agencies including State higher education agencies as defined in 20 U.S.C. 1003(22).

Yes, you may contract a private, for-profit organization for the purpose of obtaining goods and services for the recipient's use and creates a procurement relationship with a contractor.

63. If an applicant proposes subawards, where in the application should they include the subaward budget?

The budgeted amount for a subaward will go in the "Contractual" line item of the lead applicant’s ED-524 Budget Summary Form. The specific details of each subaward must be provided in a separate, detailed budget narrative for each year of the project period.

64. Does the 8% indirect cost rate apply to subgrants as well?

Yes. Sub awardees, must comply with the administrative requirements of the award, including the indirect cost rate limitations outlined in 2 CFR 200.332 Requirements for pass-through entities, particularly the requirements for pass-through entities. This includes Indirect Cost Rate Identification as per 2 CFR 200.332(b)(1)(xiv) and the review and approval process for indirect cost rates specified in 2 CFR 200.332(b)(4).

If a subrecipient has an indirect cost rate that exceeds 8% of Modified Total Direct Costs, their rate must be capped at 8% of Modified Total Direct Costs like the awardee (passthrough entity).

65. Is the partners section of the narrative meant to include only sub awardee partners?

You should include the key players on the grant – SEA,…