3 considerations for prison education programs


3 considerations for prison education programs

What you need to know ahead of July’s restoration of Second Chance Pell grants


Given the restoration of Pell Grant funding for incarcerated students on July 1, many institutions are beginning to develop plans for Prison Education Programs (PEPs). However, before building new programs, institutions should carefully consider the needs of this population as well as the regulatory requirements intended to protect them from predatory practices. (Scroll to the bottom of this post for details on eligibility and approval.)

In addition to this detailed report from the Department of Education, we've compiled key program requirements and best practices from two campuses, Mott Community College and Ferris State University, who are partnering on an impactful PEP transfer pathway for incarcerated students in Michigan.

-Mary Cusack, Second Chance Pell Program Coordinator, Mott Community College

Building a PEP transfer pathway

In 2015, Mott Community College developed a partnership with the Thumb Correctional Facility in Lapeer, Michigan to offer associate degree programs as part of the Department of Education’s Second Chance Pell Experimental Sites initiative. Building on their early success, Mott’s Second Chance Pell Program Coordinator, Mary Cusack, recently turned to a long-standing transfer partner in the region, Ferris State University. Together, Mott and Ferris have tailored an existing business administration transfer pathway to deliver to students at the Thumb Correctional Facility beginning in Fall 2024. Through this transfer pathway, students will receive their associate degree enroute to their bachelor’s in business administration.

In addition to the expansion of Pell to incarcerated students, this partnership comes on the heels of  Michigan’s Clean Slate Laws—enacted in April 2021. These laws collectively expanded eligibility for expungement and streamlined record sealing processes for eligible convictions (learn more here). Given the extensive barriers individuals with criminal convictions face accessing employment, these policy interventions increase the likelihood of positive workforce placement upon completion of a degree. For administrators at Mott and Ferris, the timing was right to partner on a PEP that can help rebuild communities impacted by the criminal justice system.

Best Practices

Explore the 15 student success best practices that power the Moon Shot initiative.

3 considerations for creating a PEP

1. Modality

While campuses are more prepared than ever to deliver remote instruction and may be enticed by online, asynchronous modules, institutions must be mindful of the needs of the population they are serving. Many incarcerated students have not finished formal education and may require greater support. Additionally, online learning inhibits community building, which is particularly important for this demographic.

Instead of asynchronous online modules, Mott and Ferris classes are offered in-person at the correctional facility. The delivery of high quality in-person experiences has required significant coordination of site visits and clearances for teaching faculty. However, program administrators believe this coordination is worthwhile, given the positive impact of in-person faculty interactions. While Department of Education guidelines do not mandate in-person delivery, institutions should carefully consider the modality of their PEP and ensure it centers student success.

2. Re-entry support

Institutions interested in PEPs should also consider program availability and support when students go home. Since the Mott and Ferris program is built on an existing transfer partnership, students enrolled in the program at Thumb Correctional Facility can complete their remaining credits at Ferris’ statewide and online locations across Michigan upon re-entry. Program administrators have also sought to build out wraparound support for students going home, including resources for workforce placement.

While there are many re-entry services nationwide, these resources often exist in pockets, are regionally dependent, and require knowledgeable administrators to connect students to the services that meet their unique needs. Luckily, there are several efforts underway to streamline access. For example, the Calvin Prison initiative created an online map for employment opportunities, food pantries, and other re-entry services.

Mary Cusack keeps her own records of re-entry support services as well as employers willing to work with students who are going home. In addition, she has partnered with her colleagues to ensure that students can leverage existing campus resources upon re-entry. For example, Mott’s Lenore Croudy Family Life Center offers a food pantry and clothing closet, and also staffs social workers who can guide students through available state benefits. In addition, Mott’s Workforce and Economic Development division partners with Michigan Works to connect students with workforce placement resources throughout the state. Behind the scenes, Mary has also worked with her colleagues to streamline processes and remove administrative hurdles to meet the needs of Second Chance Pell students.

While Michigan has been a leader in prison education, major barriers to accessing employment still exist for individuals with criminal convictions. Further policy interventions like Michigan’s Clean Slate Laws will be important to ensure Second Chance Pell students are able to access meaningful employment en route to and upon completion of credentials nationwide.

3. Mission alignment

When asked what the driving motivation was behind Mott’s Second Chance Pell work, Mary Cusack explained, “We have a responsibility to rebuild communities that have been impacted by the justice system, and one way to do that is to help increase educational attainment so that a person can access employment when they go home.” Mary views Second Chance Pell programs as vital to meeting regional workforce needs—a key pillar for many community colleges.

Ferris State University views their Second Chance Pell partnership as a natural extension of their Ferris Equity Initiative, a public-private partnership with EAB that seeks to eliminate equity gaps and improve student outcomes. Similar to other participating Moon Shot for Equity campuses, Ferris has made addressing structural barriers in the transfer student experience a top priority. In addition, Ferris draws motivation from their founders, Woodbridge and Helen Gillespie Ferris, who sought to expand access and educational attainment in the state of Michigan.

Requirements for PEPs


  • Student eligibility: Expected in July of 2023, confined or incarcerated individuals will be broadly eligible for Pell Grants upon completion of the FAFSA.
  • Institutional eligibility: Non-profit postsecondary institutions (public, private, and vocational) may offer a PEP. Institutions cannot have been the subject in the last five years to various adverse actions by the DOE, an accrediting agency, or state.


All institutions must obtain approval from an oversight entity to ensure the PEP is ruled in the best interest of the students. A state’s Department of Corrections and associated bodies typically serve as the oversight entity.

  • Best Interest Determination: The oversight entity determines if the potential PEP is operating in the best interest of students. Simply put, institutions should develop programs for incarcerated students that are broadly applicable and assist in job placement. The DOE encourages oversight entities to assess outcomes indicators such as postsecondary enrollment following release, job placement rates, and earnings for graduates.
  • Assessment: PEPs will have mandatory periodic assessment, ensuring they achieve programmatic and financial purposes for which they were authorized. (See Appendix A for assessment criteria.)
  • Two-Year Initial Approval Period: The PEP must be approved by the oversight entity within the first two years of launch. If a PEP is not determined to be operating in the best interest of confined students, the PEP will lose eligibility.

Once an oversight entity approves a PEP, the institution must submit an application to the Secretary of Education to participate in Federal Student Aid Programs. (See Appendix B for full application requirements.)

The oversight entity will typically assess:

  • Whether experience, credentials, and rates of turnover or departure of instructors for the PEP are similar to other programs at the school (accounting for unique geographic and other constraints of the PEP)
  • Whether transferability of credits/ courses available to confined or incarcerated individuals is similar to those at other programs at the school
  • Whether PEPs offerings of academic/ career advising services is similar to offerings for non-incarcerated students.
  • Whether the school ensures all formerly confined/ incarcerated individuals are able to fully transfer their credits / and continue programs at any of its locations that offer a comparable program

The application must include:

  • Detailed description of the comprehensive transition and postsecondary program that address all of the components of the program
  • Institution’s policy for determining whether a student enrolled in the program is making satisfactory academic progress
  • The number of weeks or instructional time/number of semesters or quarter credit hours in the program, including equivalent noncredit. Programs must meet instructional time minimums to comply with regulations.
    • For a program offered in credit hours, a minimum of 30 weeks of instructional time
    • For a program offered in clock hours, minimum 26 weeks of instructional time
    • Students must complete at least:
      • 24 semester or trimester credit hours or 36 quarter credit hours
      • 900 clock hours
    • Description of the educational credential offered or identifies outcome or outcomes established

In conclusion

Mary Cusack emphasized that campuses interested in the expansion of Second Chance Pell must engage for the right reasons. With a rapid expansion of PEPs this summer, there’s a risk that some institutions may view Second Chance Pell as a quick revenue stream without carefully considering the needs of this population. Oversight entities, including the Michigan Department of Corrections, do not allow students to take on loans for PEPs, which would pose a risk for a population that already experiences significant structural barriers to employment. Campuses must get creative working within narrow margins to deliver programs at cost of Pell or to attract philanthropic dollars. Therefore, it is vital for campuses to ground their motivations for developing PEPs in their core mission, values, and strategic priorities.

We hope this legislation will motivate more institutions to develop pathways for incarcerated students to pursue their educational goals. Following the lead of institutions like Mott and Ferris, you can play a role in making higher education more accessible and equitable.

Author's note: Caylie Privitere contributed to the writing of this post.

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