60D Comment Response Summary

1845-0113 60D comment response table.docx

Comprehensive Transition Program (CTP) for Disbursing Title IV Aid to Students with Intellectual Disabilities Expenditure Report

60D Comment Response Summary

OMB: 1845-0113

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60-day public comments received for information collection 1845-0113

2020-2021 Financial Assistance for Students with Intellectual Disabilities Expenditure Report

Docket number ED–2020–SCC–0168

Comment #



FSA Response

Change based on comment?


Larry Dembrum

This information is very useful and informative article of:

In 2008 Congress re-authorized the Higher Education Opportunities Act (P.L. 110 -315) with little fanfare. The Higher Education Opportunities Act (HEOA) under Title IV governs all Federal Student Aid. The re-authorization of HEOA included several significant changes to the law of which most of the public remains unaware. Prior to 2008 only students who were enrolled full-time in a college degree bearing program were eligible for Federal Student Aid. Now, there are important exceptions to this rule that even the information specialists at the U.S. government's information clearing house for financial aid have yet to be trained to able to answer questions about these exceptions.

There are a large number of students with Intellectual Disabilities (ID) who are academically capable of the rigors of a vocational program or college credit bearing coursework, but deficits in executive functioning, social skills, and/ or independent living skills prevent them from enrolling at college or vocational program full-time. Many of these students will have labels such as Asperger syndrome, Pervasive Developmental Disorder-Not Otherwise Specified (PDD-NOS), and Attention Deficit Disorder (ADD) or Attention Deficit Hyperactivity Disorder (ADHD). Without financial support a number of these students cannot purse postsecondary education and training.

HEOA allows an eligible student with an intellectual disability (ID) attending an eligible comprehensive transition and postsecondary (CTP) program to receive: (1) Federal Pell Grant, (2) Federal Supplemental Education Opportunity Grant, and (3) Federal Work-Study programs funds. Currently, no student loans are available to students with ID. To access the aid, a student with an intellectual disability applies through the Free Application for Federal Student Aid (FAFSA), just like his or her neurotypical peers.

An eligible student with an intellectual disability (ID) is defined in section 760 of the HEOA (with slight modifications) and includes a student: (A) with mental retardation or significant cognitive impairment AND (B) who is/was eligible for FAPE under IDEA including students who were private and/or home-schooled students. The student must be enrolled in an approved CTP Program and must meet all of the general student eligibility requirements under section 668.32 EXCEPT:

Does NOT have to be enrolled for the purpose of obtaining a degree or certificate
Is NOT required to have a high school diploma or have passed an ability-to-benefit test
Must maintain satisfactory academic progress under school's policy for students in the CTP
The student must also have documentation demonstrating that he or she has an intellectual disability.

Larry Dembrun

FSA thanks the commenter for taking the time to review our information collection renewal. As there was no suggestion for changes to the burden estimates as identified, FSA is not making any adjustments to the information collection.




Help these ppl get awY from me

Outside the scope of the information collection. No response.



Rani Teknokrat

Hello, it's a nice post, please visit my website too.. www.teknokrat.ac.id

Outside the scope of the information collection. No response.




Disabled students, with either emotional, developmental or idiopathic intellectual disabilities are draining a lions share of resources away from students with more aptitude and capacity to learn. These developmentally disabled or emotionally challenged students are disruptive and require resources that our educational system are ill equipped to provide. Oftentimes a single student will require one-on-one staffing to simply get through the day without harming him or herself and others. At this point their "education" is simply an elitist form of custodial care that has brainwashed intellectuals believing that therapeutic or progressive learning is taking place when in reality these children and youth are merely in a cage without bars, where the 99% of the student populations are held hostage in an environment full of disruptive disabled children who interrupt literally every moment of the educational process with outbursts and uncontrolled biological processes, saliva, vomit, urine, and feces are frequently airborne and fill the environment during class, lunch, hallway, recreation and other activities.

Disbursing further aid disregards the problem at hand- the "rights" of the disabled now greatly impair and prevent the rights of the able to secure the most basic ability to get a public education. I speak not as a disgruntled parent, but as a professional who has provided services to these unfortunate disabled students. These disabled children and youth need an environment more tailored to their needs and that is not the halls and classrooms of a public school. These children need a medicalized secure environment with long term care options for custodial type care where their needs can be addressed safely, where biological fluids can be managed in a sanitary fashion and their outbursts can be contained without endangering or exposing the general population of students.

The dignity of the disabled should not override the few basic needs of the able to receive a safe, uninterrupted lesson free of airborne bodily secretions and the verbal and nonverbal cries of the tragically disabled.

Please look to developing separate educational and residential facilities fir the disabled.

The disabled present a severe challenge to our society and forcing them to remain home only destroys the existing family structure, their needs and requirements tear apart families causing divorce, abandonment, poverty and insecurity for the remaining healthy children and adults who go on to have a laundry list of physical and emotional consequences that provides a far greater drain on the health and human services departments and finding than has been offset by the "humane" method of requiring the child to live at home and attend school as if he or she were a "normal" child.

At first my words may seem harsh and extreme, but each disabled child affects the lives of the surrounding so profoundly that it is like setting off a slow destructive force within the center of a family and community that will slowly but surely destroy the lives of those first in close proximity and radiating outward. Facilitating the destruction of the innocent in search of a humane treatment for one only leads to a spread of dysfunction and causes costs incalculable that persist many generations.

Please rethink this regulation.

FSA thanks the commenter for taking the time to review our information collection renewal. Because the Higher Education Act of 1965, as amended, incorporated eligibility for post-secondary funding for students with intellectual disabilities, and only an act of Congress could remove or modify such eligibility. As there was no specific suggestion for changes to the burden estimates as identified, FSA is not making any adjustments to the information collection.



Shyla Patera

My name is Shyla Patera. As an advocate for Montana is with disabilities, I hope that this information collection will assist the department of education as they find assistive technology in the classroom, learning eniviroment and beyond. I believe that questions and assessments should be taken regarding academic and life transitions not only in the school system, but how our employment and community living systems are assisting students as many strive toward community living and competitive integrated employment in their states and communities. As states and school districts, administrators should be questioning whether States and communities are truly promoting competitive integrated employment and wages. States, school districts ,vocational rehabilitation systems, parents, and advocates should be working and implementing conversion plans which would lead toward competitive integrated employment and wages.

FSA thanks the commenter for taking the time to review our information collection renewal. This collection is used to capture the funding information for an institution that has students with intellectual disabilities who are receiving Title IV student financial assistance. It is not an assessment of the educational program. As there was no suggestion for changes to the burden estimates as identified, FSA is not making any adjustments to the information collection.


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