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Integrated Pell Grant Expansion and Bachelor’s Completion Pay for Performance:

A Cost-Effectiveness Analysis

Harrison G. Holcomb

William T. Drier

School of Public Affairs

University of Colorado – Denver

Author’s Note: The authors wish to thank Todd Ely Ph.D. Assistant Professor, Jane Hansberry

Ph.D. Scholar-in-Residence, Benoy Jacob, Ph.D. Assistant Professor, Paul Teske, Ph.D. Dean,

and Amanda Buchanan, MPA Candidate, for providing us with their invaluable assistance. Our

participation in this competition is sponsored by the School of Public Affairs at UC-Denver.

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Executive Summary Improving both overall bachelor’s degree completion rates and equity in those completion rates

between low-income citizens and others should be a policy priority for the United States at the

national level. The slow growth in the credential completion rate and the gap in bachelor’s degree

completion between the wealthiest and poorest Americans threatens both economic growth and

the strength of democratic principles in government. This memo evaluates the cost effectiveness

of implementing two integrated policy solutions that focus on improving equity in educational

attainment as a way to boost bachelor’s degree completion in the United States. The first is an

expansion of the existing Pell Grant program to cover the costs of concurrent enrollment programs

for low-income high school students. Participation in concurrent enrollment has been shown to

considerably increase the probability of both attending university and obtaining a degree. The

second is the launch of a voluntary pay for performance initiative for four-year institutions to

incentivize closing the current degree completion gap between low-income students and their

better off peers. These initiatives are designed to work in tandem to improve educational

attainment for low-income students from all backgrounds. We project that in the ten year period

between 2017 and 2027, these policy solutions can generate a total of up to 2.3 million new

bachelor’s degrees for a total cost of about $3.45 billion. The rationale of our approach is

summarized in the logic model presented in Figure 1 below:

Figure 1: Integrated Pell Expansion and Pay for Performance Theory of Change Logic Model

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Understanding the Challenge of Degree Completion

The target population: low income students

Low-income students comprise a large and increasing portion of both secondary and

postsecondary students in the United States. The Department of Education reports that the

percentage of secondary students who qualify for free or reduced price school lunch, a common

proxy for poverty, increased from about 38% in 2001 to 51% in 2013.1 Similarly, the percentage

of students qualifying for Pell grants, which are based on family or individual income, have held

steady at about 60% of applicants for federal financial aid.2 Also, the number of students reporting

family incomes below $30,000 has increased.3 This low-income population often faces multiple

barriers to success in postsecondary education, including a higher probability of being first-

generation students, members of disadvantaged minority groups, or dependent care

responsibilities. Low-income students also vary in age, with adult learners more common in this

population.4 Research in this population has also indicated higher levels of sensitivity to the costs

of higher education, meaning that the presence or absence of financial aid, and how that aid is

packaged have a disproportionate impact on their decision-making for further education.5,6

The impact of underachievement

As a result of these barriers, low-income students complete postsecondary education at much lower

rates than their better off peers. The Pell Institute reported that in 2015, while 77% of dependent

students in the top income quintile for the United States completed a bachelor's degree within six

years, only 9% of students in the bottom income quintile hit the same benchmark.7 The Education

Trust indicates that at all levels of academic promise, and across all institutional types, students

who receive Pell Grants perform worse than their better off peers.8 Since students fitting the low-

income profile represent a significant portion of current and future postsecondary students, this

inequity in completion rates has a significant negative impact on overall completion rates.

Impacts on society

This poor postsecondary completion rate and its disproportionate impact on low-income students

has a negative impact on U.S. economic growth, weakens democratic participation, and can be

associated with poorer population health outcomes. Higher levels of education among workers are

associated with higher wages and greater worker productivity, leading to increased rates of

economic growth.9,10 Further, low levels of education reduce income for those workers, negatively

impacting both the equity and efficiency of the economy. A general level of equity in educational

attainment is also important to maintaining democratic principles of governance, since an ability

to both access and interpret information about issues facing the state is essential for all citizens.11

Citizens with considerably lower levels of educational attainment will be less able to engage in

this core democratic activity, meaning disparities in education lead to disparities in democratic

participation.

The importance of the bachelor’s degree credential

There are a variety of first level postsecondary credentials available to students, including technical

certificates, associate’s degrees, or a bachelor’s degrees. Since the problem is rooted in concerns

about democratic participation and economic equity and efficiency, it makes sense to target the

bachelor’s credential as it is associated with the strongest increases in earnings potential.12,13

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Thus, increasing this credential could reasonably be expected to have the most long-term impact

on improving equity.

Concurrent Enrollment: A Proven Strategy to Improve Educational Outcomes

Concurrent enrollment programs, which allow high school students to take college courses jointly

with high school classes, have been widely implemented across the United States, with all 50 states

documenting some concurrent enrollment programs operating at the local level.14 47 states have

also established state level policies and guidelines. These programs take a variety of forms.

However, the predominant model, used by more than 60% of programs, allows high school

students to take college-level courses taught by college faculty either on campus or at their high

school.15 Participation in concurrent enrollment has been associated with a variety of benefits for

students including: increased high school graduation rates, higher rates of enrollment in

postsecondary education, higher postsecondary graduation rates, and reduced time to degree.16

One analysis conducted on students in the University of Texas system found that participants in

concurrent enrollment graduated from college at a rate of 65%, and at a median time of 4.15

years.17 Another study, conducted at Boise State University also found positive outcomes for

students that participated in concurrent enrollment programs including improved academic

performance.18

However, despite widespread implementation, participation in concurrent enrollment remains

comparatively low, particularly among low-income students. The US Department of Education

reports that in 2013 only 8% of US students participated in concurrent enrollment with local

universities.19 Further, in the state of Colorado, low-income students (defined as those receiving

free or reduced price lunch) were considerably underrepresented, participating at about half the

rate of their better off peers.20 These low participation rates and disparities in participation mean

that the potential benefits of concurrent enrollment programs are not being realized.

One reason for this underuse of concurrent enrollment is the lack of guaranteed funding for tuition,

fees, textbooks, and transportation required of participants. Particularly to those who are more

sensitive to educational costs than higher income peers, as noted by both Heller and St. John.21,22

Only 15 states provide any state-level funding for concurrent enrollment programs, with others

leaving it to the discretion of local school districts to fund.23 Among the states that do provide any

funding, even fewer cover all costs or target low-income students. This results in more limited

program implementation and presents a barrier to low income students.

Filling the Concurrent Enrollment Funding Gap: Pell Expansion Program The Pell Grant program was launched for the 1973-4 academic year, with the purpose of providing

financial support to low-income students pursuing postsecondary education. The program is

administered by the Department of Education, under authority granted to the department by the

Higher Education Act.24 In order to be eligible for a Pell Grant under the current system, a student

must be enrolled at least part time at postsecondary school eligible to receive federal aid and

complete a Free Application for Federal Student Aid to demonstrate financial need.25 Pell grants

are made on a sliding scale, based on the student’s ability to pay, number of credits attempted, and

the expected educational costs.26 Under current policy, students participating in concurrent

enrollment programs are not eligible to receive Pell grants or any other form of federal financial

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aid to cover costs. This is despite the fact that most students participating in concurrent enrollment

programs are at schools that meet the institutional eligibility criteria for Pell, specifically the rule

that the coursework must count toward some academic program that can lead to a credential,

including a bachelor or associate degree.27

Our proposal would expand the Pell Grant program to include high school seniors participating

in concurrent enrollment programs at institutions eligible to receive federal aid dollars. The

requirement to complete a FAFSA to demonstrate need and document enrollment would remain

the same, however students would be entitled to up to one academic year of additional eligibility

for concurrent enrollment which would not be counted toward the six years of postsecondary

eligibility that students are currently granted.

Other aspects of the program, including award calculation procedures and funding allocations for

administration by colleges and universities would remain largely unchanged. The only difference

being that concurrent enrollment students would be treated as full time enrollees for the purposes

of award calculation. Pell grants are subject to the same caps based on total expected costs as other

forms of federal aid, meaning the grant cannot exceed the total educational costs reported by the

institution.28 As a result, Pell grants for high school students are likely to be smaller than for

traditional postsecondary students, as they would be taking fewer credits and many states have

established tuition discounts at public institutions, or created fee exemptions for concurrently

enrolled students.29

The expansion would specifically target low-income students for participation in concurrent

enrollment programs, while also offering a general level of federal support for concurrent

enrollment. This proposal represents a scaling up of an existing experimental program launched

by the Department of Education in 2015, which provides grant money to postsecondary institutions

to implement concurrent enrollment initiatives targeted at Pell eligible students.30

Benefits of a Pay for Performance Approach to the Pell Completion Gap

Adopting a pay for performance model to address the completion gap between Pell recipients and

other students offers three advantages in comparison to traditional federal grant making efforts: it

increases efficiency in expenditure, encourages innovation at participating institutions, and ensures

sustainability for the new programs. These benefits have been documented in other initiatives in

the social sector.31 These advantages are particularly important in attempting to address the

challenges of Pell grant recipients, who are a diverse population that often faces additional

challenges impacting persistence in addition to low income. These challenges include: first-

generation student status, membership in a disadvantaged minority group, or responsibility for

dependents.32

A pay for performance model changes the incentives of traditional grant making by paying the

recipient only after agreed upon outcomes are achieved, rather than in advance based on a proposed

set of outputs. In the case of Pell recipient degree completion, this approach focuses federal

spending only on actual improvements in the completion gap, and encourages schools to maximize

efficiency.

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This model also allows schools greater flexibility in choosing which program investments it feels

will most efficiently achieve outcomes. This will encourage both innovation and diversity in

interventions. Since these interventions are likely to be tailored to the particular characteristics of

an institution’s population, they are also likely to have benefits for non-Pell recipients who may

share some of the additional barriers faced by many Pell students.

In addition, a pay for performance approach will yield more sustainable projects, since institutions

must rely on existing funds to implement their program activities. Programs that rely on internally

allocated funds would be more likely to continue even when pay for performance funds are reduced

or eliminated. Further, the pay for performance funds are not earmarked for particular activities.

Therefore, there is even less of a contingent relationship between the availability of federal dollars

and institutional activities. Even if incentive funds are received, they need not be spent on the

programs that generated them.

Pay for performance represents an efficient, innovative, and sustainable approach for the federal

government to take in addressing the bachelor’s degree completion gap between Pell recipients

and other students.

Implementing Pay for Performance

The degree completion gap is a serious issue the Pell Grant program faces when measuring its

success. A study conducted by the Education Trust found a 14% gap between Pell and non-Pell

students national college completion rate (51% to 65%).33 The Department of Education found a

similar rate which falls between 15-20%.34 However, since institutions that receive Pell Grants are

not required to disclose information on graduation rates for Pell recipients, more specific data is

not available. We propose implementing a pay for performance program for Title IV bachelor’s

degree granting institutions. The program would have two goals, first to move Pell students toward

parity in college graduation with their higher-income peers, and second to better understand what

interventions are likely to achieve this goal at the institutional level. The objective of this program

is to spur innovative and situation-specific solutions to addressing this gap, specifically for the

group of students who are not able to

benefit from concurrent enrollment

credits via the Pell Expansion

Program. Thus, schools would not be

compensated for any degrees earned

by Pell recipient students who also

received a Pell Expansion Program

grant. This would both control

program costs, and ensure a more

equitable allocation of resources

among different groups of low-

income students.

In order to address the gap, our Pay

for Performance program would

invite all bachelor’s degree granting

Gap is ≤ 3%30%

Gap is > 3%70%

Figure 2. Percent of students at institutions by Pell/non-Pell completion gap

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Title IV institutions to participate. According to the Educational Trust this represents

approximately 3000 institutions.35 Approximately 35% of schools have completion gaps of 3% or

less, and thus would be unlikely to participate.36 However, the remaining 2100 institutions likely

to participate serve 70% of the undergraduate student population.37 The reach of the program is

summarized in the graph to the right. Participating schools would sign performance agreements

that would offer to compensate the schools at a rate of $4,000 per additional degree earned by a

Pell grant recipient, excluding any Pell recipient students who also received a Pell Expansion

Program grant. Payments begin at an improvement of 1% and up to parity in their Pell vs. non-

Pell student six-year graduation rate. These performance dollars will be paid out at the close of the

six-year performance cycle. This is designed to give schools the opportunity to have at least one

cohort of students reap the full benefits of any interventions for the full period of Pell grant

eligibility.

Following the close of the initial six-year program period, an evaluation of outcomes and current

status of the completion gap between Pell and non-Pell students will be conducted using the

dramatically increased volume and quality of data on Pell student graduation rates in comparison

to the current information. This would provide an opportunity to evaluate how to better target

institutions in future pay for performance arrangements. This period of evaluation would also

allow for better assessment of the role of the Pell Expansion Program in improving completion

rates and achieving parity between Pell and non-Pell students.

Analyzing the Cost-Effectiveness of Integrated Pell Expansion and Pay for Performance

We conducted a cost-effectiveness analysis to determine the efficiency of the interventions. Cost-

effectiveness analysis uses projections of potential costs as well as possible benefits to determine

the cost per outcome of an intervention. In this case, the desired outcome is additional college

degrees, and the proposed interventions are an expansion of the Pell Grant program and a pay for

performance program for four-year colleges. The costs are those associated with making additional

grants available to high school students participating in concurrent enrollment through the Pell

program and the payment of performance incentives for universities that narrow the completion

gap. In developing our forecasts for costs and effects of each intervention, we relied on a variety

of assumptions and parameters about demographic trends, participation in higher education, and

costs which are summarized in two tables below:

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Table 1. Pay for Performance Program Assumptions

Assumptions Source

# of students enrolled in postsecondary

education (PSE) (2017) 11,022,000 National Center for Education

Statistics (NCES)

65% of institutions represent 70% of

students 80% Education Trust

College graduation rate of Pell students 51% Education Trust

College graduation rate of non-Pell

students 65% Education Trust

National education gap 12% Education Trust

FAFSA application rate 85% Office of Federal Student Aid

(OFSA)

Pell eligible rate 60% OFSA

Pell accepting rate 80% OFSA

Table 2. Pell Expansion Program Assumptions Assumptions Source Concurrent enrollment participation

growth rate- no intervention 0.5% National Center for Education

Statistics (NCES)

% high school (HS) grads to PSE 70% Bureau of Labor Statistics

(BLS)

# of HS Grads 3,328,740

NCES projection through 2023,

~0.2% average growth rate

2024-2027 Concurrent enrollment participation

growth rate- intervention 4% Jobs For the Future (JFF) report

on Colorado CE goals

Concurrent enrollment success rate 93% Colorado Department of Higher

Education Concurrent enrollment graduation rates 65% ACT Non-concurrent enrollment graduation

rates 59% NCES HS to PSE rate 66% BLS # eligible HS seniors 4,058,000 US Census Bureau

Adoption rate 4% of student population

adopts per year JFF report on Colorado CE

goals

Minimum Pell award $599.82 Office of Federal Student Aid,

1% growth rate per year

Discount rate 0.9% Office of Management and

Budget

Apply for FAFSA 85% Office of Federal Student Aid

(OFSA) Pell eligible rate 60% OFSA Pell accepting rate 80% OFSA

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Intervention Costs: Grants and Incentives

The primary costs associated with our interventions are the additional Pell grants made to high

school students through the Pell Expansion Program, and the potential payments made to schools

through the pay for performance initiative.

Pell Expansion Program

The baseline cost for Pell Grants is set at the minimum potential award for each year, which begins

at $599, and has consistently increased by about 1% per year in the past five years. 38 Our

justification is that students eligible for the Pell Grant will be earning credits in a part-time capacity

they will not have to worry about cost of living, and credits obtained through concurrent enrollment

are usually discounted for high school students within most current local level program support.

In fact, the Department of Education reports that more than half of institutions that have concurrent

enrollment students offer some discounting.39 For the purposes of this analysis, we also assume no

major change in state and local level funding for concurrent enrollment programs.40

𝐶𝑜𝑠𝑡 𝑓𝑜𝑟 𝑑𝑒𝑔𝑟𝑒𝑒𝑠 = 𝐸𝑙𝑖𝑔𝑖𝑏𝑙𝑒 12𝑡ℎ 𝑔𝑟𝑎𝑑𝑒𝑟𝑠 ∗ 𝐶𝐸 𝑎𝑑𝑜𝑝𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 ∗ 𝑃𝑒𝑙𝑙 𝑎𝑐𝑐𝑒𝑝𝑡𝑖𝑛𝑔 𝑟𝑎𝑡𝑒 ∗

𝑃𝑒𝑙𝑙 𝑎𝑤𝑎𝑟𝑑 𝑎𝑚𝑜𝑢𝑛𝑡

Pay for Performance Program

The $4000 paid per new degree is based on a median value from other equity achievement grants

provided to postsecondary institutions by the federal Fund for the Improvement of Post Secondary

Education.41 In the table below we project total program costs based on various levels of

organizational performance, ranging from 5% to a maximum of 30%, which would approximately

reach parity in college completion. We

anticipate performance outcomes at about

5% on average across all institutions,

based on analysis of the general trends and

variance in bachelor’s degree completion

rates.

𝐶𝑜𝑠𝑡 𝑓𝑜𝑟 𝑑𝑒𝑔𝑟𝑒𝑒𝑠 = 𝑃𝑒𝑙𝑙 𝑠𝑡𝑢𝑑𝑒𝑛𝑡 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 ∗ (𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 𝑖𝑚𝑝𝑟𝑜𝑣𝑒𝑚𝑒𝑛𝑡 −

𝑝𝑟𝑒𝑣𝑖𝑜𝑢𝑠 𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒) ∗ $4000

Approach to discounting costs

In evaluating both interventions we use a discount rate of 0.9% which is recommended by the

Office of Management and Budget (OMB) for cost-effectiveness analysis.42 This is considerably

more conservative than the 3.0-3.5% rate used in academic cost-effectiveness studies of education

policy interventions.43,44 Potential variance in the actual discount rate, which is typically adjusted

annually by OMB, would have an impact on the actual cost of the program.

Table 3. Pay for Performance Sensitivity Analysis

Gap Closure % Degrees Cost

30% 453,300 $1,913,300,000

15% 226,600 $956,460,000

5% 75,550 $319,000,000

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Effect: Additional Bachelor’s Degrees

Pell Expansion Program

The chart below summarizes the number of additional degrees anticipated as a result of the Pell

expansion program. We determined the number of degrees by calculating the difference in total

degrees per year with enhanced adoption of concurrent enrollment supported through Pell

expansion, and the existing trend in completion rates with no intervention. The additional degrees

are visualized in the following graph:

The formula is provided below:

𝐷𝑒𝑔𝑟𝑒𝑒𝑠 𝑒𝑎𝑟𝑛𝑒𝑑 = (𝐸𝑛𝑡𝑒𝑟𝑖𝑛𝑔 𝑃𝑆𝐸 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 ∗ 𝐶𝐸 𝑝𝑎𝑟𝑡𝑖𝑐𝑖𝑝𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 ∗ 𝐶𝐸 𝑠𝑢𝑐𝑐𝑒𝑠𝑠 𝑟𝑎𝑡𝑒 ∗

𝐶𝐸 𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒) + (𝐸𝑛𝑡𝑒𝑟𝑖𝑛𝑔 𝑃𝑆𝐸 𝑝𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 ∗ (𝑁𝑜𝑛𝐶𝐸 𝑝𝑎𝑟𝑡𝑖𝑐𝑖𝑝𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 +

𝐶𝐸 𝑓𝑎𝑖𝑙 𝑟𝑎𝑡𝑒) ∗ 𝑁𝑜𝑛𝐶𝐸 𝑔𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒)

We further conducted sensitivity analysis to determine the potential impact of variance in the

adoption rate for concurrent enrollment on the

number of additional degrees earned, using

adoption rate data from Colorado as a proxy.45

Colorado was selected as it has implemented a

funding model similar to Pell at the state level.46 We

find that 4%, which is what Colorado projects to be

the most likely outcome, as the state has consistently

seen increases above 3%.47

Pay for Performance

During its six-year cycle, we calculated the additional degrees generated by the Pay for

Performance program based on national estimates of the total volume of improvement in the

completion gap across all participating institutions. Using data from the Department of Education,

1000000

1100000

1200000

1300000

1400000

1500000

1600000

1700000

2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027

Figure 3: New Degrees from Pell Expansion

Expected Degrees PEP Degrees

Table 4. Pell Expansion Program Sensitivity

Analysis

Adoption Rate Degrees Cost per Degree

2% 684,500 $ 4,600

4% 2,258,700 $ 1,400

6% 2,803,700 $ 1,100

11

we estimate that the overall improvement will be a 5% reduction in the completion at participating

schools, generating an additional 75,500 degrees over six years.

𝐷𝑒𝑔𝑟𝑒𝑒𝑠 𝑒𝑎𝑟𝑛𝑒𝑑 = # 𝑠𝑡𝑢𝑑𝑒𝑛𝑡𝑠 𝑒𝑛𝑟𝑜𝑙𝑙𝑒𝑑 2017 ∗ 70% 𝑜𝑓 𝑒𝑙𝑖𝑔𝑖𝑙𝑏𝑒 𝑠𝑡𝑢𝑑𝑒𝑛𝑡𝑠 ∗𝑃𝑒𝑙𝑙 𝑎𝑐𝑐𝑒𝑝𝑡𝑎𝑛𝑐𝑒 𝑟𝑎𝑡𝑒 ∗ 𝐺𝑟𝑎𝑑𝑢𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 𝑜𝑓 𝑃𝑒𝑙𝑙 𝑠𝑡𝑢𝑑𝑒𝑛𝑡𝑠 ∗ 𝐺𝑎𝑝 𝑐𝑙𝑜𝑠𝑢𝑟𝑒 𝑟𝑎𝑡𝑒

Results

In the ten-year period between 2017 and 2027, we anticipate that our combined interventions will

yield a total of 2.3 million degrees for a total cost of about $ 3.45 billion. These additional degrees

represent a 14% increase, compared to expected number of degrees with no intervention. The full

results are summarized in the table below:

Table 5. Summarized Results

Intervention Cost 2017-2027 # Degrees 2017-2027 % New Degrees

Cost per Degree

Pell Expansion $3,100,000,000 2,250,000 13% $1,460 Pay for Performance $345,000,000 75,500 1% $4,000 Integrated $3,445,000,000 2,300,000 14% $1,500

Conclusion

The combination of the Pell Expansion Program for concurrent enrollment with the Pay for

Performance program represent an evidence-based and cost-effective approach to the dual

challenges of low postsecondary completion rates and income based disparities in college

completion. These problems limit economic growth and erode the democratic foundations of the

US government. This proposal leverages the existing successes of concurrent enrollment programs

and pay for performance programs to improve equity in college graduation, and thus fuels robust

growth in overall college completion. It is particularly effective since it manages to broadly target

low-income students of all ages, as well as creating incentives for the expansion of concurrent

enrollment and improved support services for all students. Thus, this policy can cost-effectively

help the United States meet the need for a globally competitive workforce, thriving economy, and

robust democracy.

12

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Denver, CO. Retrieved at: http://ecs.force.com/mbdata/mbprofallRT?Rep=DE14A 15 ibid, note 14. 16 Cassidy L., Keating K., Young V. (2012). Dual enrollment: lessons learned on school level lessons

learned on school-level implementation. EDJ Associates: Herndon, VA. 17 Radunzel J., Noble J., Wheeler S. (2014). Dual credit/dual enrollment coursework and long-term

college success in Texas. ACT: Iowa City, IA. 18 Belcheir, M. J. (2008). What happens to concurrently enrolled high school students who attended boise

state university during high school? Office of Institutional Research. Boise, ID. Retrieved at:

http://ir.boisestate.edu/wp-content/uploads/2011/07/rr200803concurrentenrollmentstudy.pdf 19 United States Department of Education (2013). Dual enrollment programs and courses for high school

students at postsecondary institutions: first look. Institute for Education Statistics

Washington, DC 20 Colorado Department of Education, Colorado Department of Higher Education (2015). Annual report

on concurrent enrollment 2013-2014 school year. Division of Central Services: Denver, CO. 21 ibid note 5 22 ibid note 6

13 23 ibid, note 14. 24 20 U.S.C. Ch. 28 SubCh, IV. Part A § 1070 25 30 C.F.R. § 690 26 Office of Federal Student Aid. (2015). 2015-2015 Federal Student Aid Handbook (Vols. 1, 3).

Washington, DC: US Department of Education. 27 ibid, note 14. 28 ibid, note 26. 29 ibid, note 14. 30 80 F.R. 67734 31 The Non-Profit Finance Fund (2012). Pay for Success: Investing in what works. Washington, DC

Retrieved at: http://permanent.access.gpo.gov/gpo23617/pay_for_success_report_2012.pdf 32 Ibid note 3. 33 ibid note 8. 34 U.S. Department of Education, National Center for Education Statistics, 2003-04 Beginning

Postsecondary Students Longitudinal Study, Second Follow-up (BPS:04/09). 35 ibid note 8. 36 ibid note 8. 37 ibid, note 8. 38 ibid, note 26. 39 ibid, note 19. 40 ibid, note 16. 41 United States Department of Education (2015). Fund for Innovation in Postsecondary Education

Database [Data Set]. Retrieved at: http://fipsedatabase.ed.gov/fipse/search.cfm 42 Office of Management and Budget. (2014). Circular A-94 Appendix C. Retrieved at:

https://www.whitehouse.gov/omb/circulars_a094/a94_appx-c/ 43 Levin, H., Belfield, C., Muennig, P., Rouse, C. (2006). The cost and benefits of an excellent education

for all of America’s children. Columbia University. New York, NY. Retrieved at:

http://www3.nd.edu/~jwarlick/documents/Levin_Belfield_Muennig_Rouse.pdf 44 Hollands, F.M., Hanisch-Cerda, B., Levin, H. M., Belfield, C.R., Menon, A., Shand, R., Pan, Y., Bakir,

I., & Cheng, H. (2015). CostOut - the CBCSE Cost Tool Kit. Center for Benefit-Cost Studies of

Education, Teachers College, Columbia University. Retrieved from: www.cbcsecosttoolkit.org 45 Ibid note 20. 46 Ibid note 20.

47 Ibid note 20.